Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services : final report.
Date: 2024-06-27
Institutions: Directorate-General for Communications Networks, Content and Technology
Subjects: EU Member State, European audiovisual area, Iceland, Liechtenstein, Norway, application of EU law, artistic creation, audiovisual industry, audiovisual production, audiovisual programme, broadcasting, business model, cloud computing, data collection, digital content, digital distribution, directive (EU), film production, legislation, mystery shopping, provision of services, report, television

Study on the implementation of the 
provisions of the revised AVMSD 
concerning the promotion of European 
works in audiovisual media services 

Final report 

Written by 
Kantar Public: Marius MOSOREANU, Vlad PODOBEA, Madalina NUNU,  
Osmo JARVI, Ivona KORONTHALYOVA 
VVA: Alessandra INNESTI, Cécilie JACOB, Adam ZAGONI-BOGSCH 
SMIT VUB: Tim RAATS, Catalina-Mihaela IORDACHE, Marlen KOMOROWSKI 
Aarhus University: Cathrin Helen BENGESSER 

 
EUROPEAN COMMISSION 

Directorate-General for Communications Networks, Content and Technology 
Directorate I — Media Policy 
Unit I.1 — Audiovisual and Media Services Policy 

Contact:  CNECT-I1@ec.europa.eu 

European Commission 
B-1049 Brussels 

 
 
EUROPEAN COMMISSION 

Directorate-General for Communications Networks, Content and Technology 

2024 

EN 

 
 
 
 
EUROPEAN COMMISSION 

Study on the implementation of 
the provisions of the revised 
AVMSD concerning the promotion 
of European works in audiovisual 
media services 
Final Report 

Directorate-General for Communications Networks, Content and Technology 

2024 

EN 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Manuscript completed in June 2024 

1st edition 

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The reuse policy of European Commission documents is implemented by Commission Decision 2011/833/EU of 
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PDF 

ISBN 978-92-68-12963-0 

doi:10.2759/513194  KK-05-24-141-EN-N 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Contents 

Abbreviations 

Executive summary 

Legislative changes concerning Articles 16 and 17 affecting linear services 

Legislative changes concerning Article 13 affecting non-linear services 

Legislative changes concerning Article 13 affecting linear services 

Monitoring and evaluation of compliance with Articles 13, 16 and 17 

8 

9 

10 

12 

13 

14 

Data reporting and application of the Commission Guidelines on the calculation of the share of European 
15 
works in on-demand catalogues and on the definition of low audience and low turnover 

The market for audiovisual works 

15 

Independent analysis of the share of European works and independent productions in linear services in 
selected 15 MS 

16 

Independent analysis of VoD services in 21 EU Member States and Norway 

Independent analysis of prominence methods used by VoD services 

Conclusions 

Résumé 

Modifications législatives relatives aux articles 16 et 17 en matière de services linéaires 

Suivi et évaluation du respect des articles 13, 16 et 17 

Modifications législatives relatives à l’article 13 en matière de services non linéaires 

Modifications législatives relatives à l’article 13 en matière de services linéaires 

17 

18 

19 

20 

22 

23 

25 

26 

Communication de données et application des lignes directrices de la Commission concernant le calcul de la 
part des œuvres européennes dans les catalogues des services de médias audiovisuels à la demande et 
26 
concernant la définition d’une faible audience et d’un chiffre d’affaires peu élevé 

Le marché des œuvres audiovisuelles 

27 

Analyse indépendante de la part des œuvres européennes et des productions indépendantes dans les 
services linéaires dans 15 États membres sélectionnés 

27 

Analyse indépendante des services de VoD dans 21 États membres de l’UE et en Norvège 

Analyse indépendante des méthodes de mise en avant utilisées par les services de VoD 

Conclusions 

1. 

2. 

Introduction 

Study methodology 

2.1  Task 1 – Legal research 

2.2  Task 1 – Member States reporting 

2.3  Task 2 – Desk research and interviews 

2.4  Task 3 – Analysis of the audiovisual content offer 

29 

30 

31 

32 

34 

34 

34 

35 

40 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

3. 

Volume 1: Implementing measures of Articles 13(1), 13(2), 16 and 17 of AVMSD 

3.1  Legislative changes affecting linear and non-linear services 

47 

47 

3.2  Overview of financial contributions to the production and the acquisition of rights of European works

64 

3.3  Overview of monitoring and evaluation processes with regard to compliance with the national 
measures implementing Articles 13(1), 13(2), 16 and 17 of the AVMSD 

3.4  Data reporting under Articles 13, 16 and 17 of the AVMSD 

3.5  Stakeholder views on the implementation of Articles 13, 16 and 17 

3.6  Conclusions 

4. 

Volume 2: The market for audiovisual works 

4.1  The size of the European audiovisual sector and its development 

4.2  Business models in the audiovisual sector 

4.3 

Investment in European works and the rights market 

4.4  Stakeholder views on the development of the audiovisual market 

4.5  Conclusions 

5. 

Volume 3: Analysis of the audiovisual content offer 

5.1  Linear services – content offer 

5.2  Non-linear service content analysis 

5.3  Non-linear services – methods to ensure prominence 

5.4  Conclusions 

Annex 1: Country fiches (Volume 1) 

Annex 2: Member States data reporting (Volume 1) 

Annex 3: Mystery shopping observation grid (Volume 3) 

Annex 4: Linear services channel list (Volume 3) 

Annex 5: Non-linear services channel list (Volume 3) 

72 

79 

88 

90 

92 

92 

100 

126 

166 

168 

171 

171 

219 

270 

282 

284 

285 

286 

292 

295 

Annex 6: Non-linear services detailed tables on share of European works  EU27 works  and UK works 
(Volume 3) 

299 

Annex 7: Audiovisual sector revenues in 2020, 2021 and 2022 (Volume 2) 

303 

 
 
 
 
 
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Abbreviations  

ARCOM 

AVMSD 

CCA 

CEE 

CNC 

DFFF 

EAO 

EBU 

EEA 

EU 

MS 

NRA 

PSB 

SVoD 

VoD 

L’Autorité  publique  française  de  régulation  de  la  communication 
audiovisuelle et numérique 

Audiovisual Media Services Directive 

Centre du Cinéma et de l'Audiovisuel 

Central and Eastern Europe  

Centre national du cinéma et de l'image animée 

Deutsche Filmförderfonds  

European Audiovisual Observatory 

The European Broadcasting Union 

European Economic Area 

European Union  

Member State(s) 

National Regulatory Authorities  

Public Service Broadcasters  

Subscription Video-on-Demand 

Video on Demand 

8 

 
 
  
  
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
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Executive summary 

This report analyses the implementation of Articles 13(1), 13(2), 16 and 17 of the revised Audiovisual Media 
Service Directive (AVMSD)1. These articles concern the promotion of European works by broadcasters and 
video  on  demand  service  providers.  The  study  is  part  of  the  regular  monitoring  which  is  requested  by  the 
Directive. The report covers the period from 1 January 2020 to 31 December 2021 and therefore the version 
of the legal provisions that were valid during that time and that entered into force in 2020. The revised Directive   
modified Article 13, while Articles 16 and 17 remain without changes.  

The study had these three objectives: 

−  Map legislative changes in Member States (MS);  

−  Provide insights on the developments in the audiovisual market; and 

−  Analyse the content offer on both linear broadcasting and on-demand services in relation to European 

works in particular.  

The study is based on the following main sources of information: 

−  Legal analysis of audiovisual legal frameworks and their evolution in 27 EU MS, as well as Norway, 
Liechtenstein and Iceland. This analysis was undertaken by independent legal experts from all covered 
countries;  

− 

reporting about the share of European works in linear services and non-linear (on-demand) services 
as provided by EU MS; 

− 

interviews with the national authorities to fill information gaps identified in the preliminary research;   

−  data from Eurostat, Orbis Europe, Mavise, TMDB datasets about the audiovisual sector and its sub-

sectors;   

−  secondary data on audiovisual business models and investment in European works; 

−  programming  data of more than 600  linear service channels in 15  EU  MS. For these channels the 
Electronic Programming Guides (EPG) data was scraped for a period of 3 consecutive months and 
subsequently analysed to assess the content offer;  

−  catalogues of 1 722 video on demand (VoD) services in 26 EU MS and non-EU countries2; 

−  mystery shopping of VoD services in 15 EU MS to collect information on prominence method used; 

−  data from Ampere on popularity of titles; 

−  qualitative key informant interviews at EU level.

1 Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending Directive 2010/13/EU on the 
coordination of certain provisions laid down by law, regulation or administrative action in Member States concerning the provision of 
audiovisual media services (Audiovisual Media Services Directive) in view of changing market realities; available at: https://eur-
lex.europa.eu/eli/dir/2018/1808/oj  

2 AD, AL, BA, CH, UK, IS, LI, MC, MD, MK, RS, SM, TR 

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Table below gives an overview of the sources of data in relation to the subsections of this executive summary.  

Sub-section 

Source  

Country coverage 

Legislative changes in relation to linear 
services  

Legislative changes in relation to on-
demand services  

Monitoring data on application of Articles 
16 and 17 

Monitoring data on application of Article 
13 

Analysis of audio-visual market 

Independent analysis of the share of 
European works in linear services 

Independent legal analysis 

EU27 + NO, LI and IS 

Independent legal analysis 

EU27 + NO, LI and IS 

Member States’ reports 

EU27 

Member States’ reports  

EU27 

Desk research (Eurostat, Orbis 
Europe)* 
Business models (Mavise, Orbis 
Europe* 
Investment in European works** 

Analysis of electronic 
programming guides for over 600 
channels  

EU27 + UK* 
EU8** 

15 selected MS 

Independent analysis of video of demand 
services  

Analysis of 751 VoD services 
catalogues 

26 EU MS + 13 non-
EU countries 

Mystery shopping (VoD services) 

Analysis of 60 VoD services 
catalogues  
Ampere analysis  

15 EU MS 

Legislative changes concerning Articles 16 and 17 affecting linear services 

The revised AVMSD did not introduce any changes to Articles 16 and 17, on promotion of European works 
and works of independent producers in relation to linear services. However, during the reference period (2020-
2021),  some  EU  MS  introduced  legislative  changes  in  relation  to  these  two  articles.  During  the  reference 
period, four Member States (AT, BE, EL, HR) introduced such legislative changes. Additionally, two Member 
States (RO, SK) made minor changes concerning Article 16 in their legislation after the reference period. 

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In accordance with Article 16, all Member States require TV broadcasters to reserve a majority proportion of 
the transmission time to European works. 21 Member States (AT, BE, BG, CY, CZ, DE, DK, EL, FI, HU, IE, 
LU, LT, MT, NL, PL, PT, RO, SE, SI, SK) and the non-EU EEA countries (IS, LI, NO) transposed the exact EU 
quotas (majority of European works), four Member States have introduced slightly higher quotas at a minimum 
of 51% (EE, ES, HR, LV), while two Member States have opted for a significantly higher quota of at least 60% 
for European works (FR, IT).  

Furthermore,  two  Member  States  oblige  public  broadcasters  to  comply  with  higher  quotas  (BE,  HU). 
Additionally, nine Member States have specific quotas on works produced in their official languages (‘works of 
original expression’) (EL, ES, FR, HR, HU, IT, LV, PL, PT). 

Similarly to Article 16, only few Member States introduced changes to Article 17. Article 17 requires Member 
States to ensure, where practicable and by appropriate means, that broadcasters reserve at least 10% of their 
transmission time for European works created by producers that are independent of broadcasters. During the 
reference period, five Member States (AT, DE, FR, HR, IT) introduced such legislative changes. Additionally, 
five Member States (ES, HR, NL, PL, SE) made amendments to their respective laws related to Article 17 of 
the AVMSD after the reference period. 

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In  six  Member  States  (BG,  FI,  HR,  HU,  IT,  SK)  the  rules  regarding  the  quota  on  transmission  time  and/or 
programming budget were higher than 10%. Furthermore, 12 Member States (BE3, CZ, ES, FI, HR, HU, IT4, 
NL, PL, PT, SI, SK) laid down specific sub-quotas for recent works.  

Four Member States (BE5, HR, HU, NL) introduced a sub-quota for works of original expression of independent 
producers. It should be noted that one non-EU EEA country, namely Norway, has also a language sub-quota. 

Legislative changes concerning Article 13 affecting non-linear services 

Overall,  national  implementation  measures  to  transpose  Article  13  of  the  revised  AVMSD  into  national  law 
were introduced in 17 Member States (AT, BE, BG, DE, DK, EL, HR, HU, FI, FR, IT, LT, LV, LU, MT, NL, PT), 
while in ten EU Member States (SE, SK, SI, IE, EE, ES, CY, CZ, RO, PL) and one non-EU EEA country (LI), 
national implementation measures came into force only after the reference period. More specifically: 

17 EU Member States (AT, BE6, BG, DE, DK, EL, FI, FR, HR, HU, IT, LT, LU, LV, MT, NL, PT) have introduced 
national implementation measures to transpose the Article 13(1) both with regard to the requirement to secure 
at least a 30% share of European works in their catalogues and to ensure prominence of those works during 
the reporting period.  It is important to note that seven out of these 17 Member States (AT, BE7, FR, HR, HU, 
IT, MT) had obligations similar to those laid down in Article 13(1) (on quotas and/or prominence) before the 
revised AVMSD. In ten EU Member States (CY, CZ, EE, ES, IE, PL, RO, SE, SI, SK)) and one non-EU EEA 
country (LI), national implementation measures came into force only after the reference period.  

The figure below illustrates these changes: 

3 French Community. 

4 Although implementing legislation was adopted after the reference period in 2022. 

5 French Community. 

6 French Community and German-speaking Community. 

7 Flemish Community and French Community. In the Flemish Community, the quota was already 30%, while the French Community had 
an obligation for VoD to provide prominence to European works (butno exact quota before the reference period). 

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Concerning  direct  and/or  indirect  financial  obligations  under  Article  13(2)  of  AVMSD,  it  is  recognised  that 
Member  States  can  require  media  service  providers  (both  linear  and  non-linear  services)  under  their 
jurisdiction  to  contribute  financially  to  the  production  of  European  works,  including  via  direct  investment  in 
content and via contribution to national funds. When such obligations exist, Member States can extend them 
to  cross-border  services  (services  that  are  not  under  their  jurisdiction  but  targeting  audiences  in  their 
territories), on condition that those contributions are proportionate and non-discriminatory.   

Seven Member States (BE, EL, FR, HR, IT, PL, PT) introduced national implementation measures during the 
reference period. 14 Member States (BG, CY, DK, EE, FI, HU, IE, LT, LU, LV, MT, NL, RO, SE) and three 
EEA  countries  (IS,  LI,  NO)  did  not  introduce  financial  obligations  for  the  promotion  of  European  works. 
Conversely, 13 Member States (AT, BE, CZ, DE, ES, EL, FR, HR, IT, PL, PT, SI, SK) had obligations for VoD 
services. Out of these 13 Member States, six Member States (AT, CZ, DE, ES, SI, SK) introduced no changes 
during the reference period, but the requirement with regard to financial contribution already existed prior to 
the reference period. At the same time, 7 Member States (BE8, EL, FR, HR, IT, PL, PT) have made changes 
related to financial contributions of  VoD services.  7 Member  States (BE, DE, EL, FR, HR, IT, PL)  reported 
having in force financial contribution obligations to cross-border services during the reference period. 

The  figure  below  illustrates  the  Member  States  and  EEA  countries  that  have  introduced  changes  linked  to 
Article 13(2) during the reference period.  

Legislative changes concerning Article 13 affecting linear services 

Besides video on demand services, Article 13(2) of AVMSD affects also linear services. 

8 French Community. 

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Regarding direct and/or indirect financial contributions for linear service providers, 16 EU Member States had 
no such requirements in place in 2019: AT, BE9, BG, CY, EE, FI, IE, IT, LU, LT, LV, MT, NL, PL, PT, RO, SE. 
The same Member States did not introduce any direct or indirect financial obligations for linear services neither 
in 2020 nor in 2021. Furthermore, 11 EU Member States have direct or indirect financial investment obligations 
for linear audiovisual service providers (BE10, CZ, DE, DK, EL, ES, FR, HR, HU, SI, SK). Two of these Member 
States  (BE11,  FR)  applied  financial  contribution  obligations  to  cross-border  linear  service  providers  by  31 
December 2021. 

Monitoring and evaluation of compliance with Articles 13, 16 and 17 

The  monitoring  and  verification  systems  of  EU  Member  States  and  non-EU  EEA  countries  with  regards  to 
linear service providers’ compliance with the national measures implementing Articles 16 and 17 AVMSD are 
illustrated in the figure below. Five Member States (AT, CY, EL, HR, SE) introduced legislative changes aimed 
at strengthening their monitoring or verification systems during the reference period.  

Note: Liechtenstein does not have a monitoring system in place 

The monitoring and verification systems in place for ensuring compliance with Article 13 are identical to their 
systems related to Article 16 and Article 17, illustrated above, in 17 EU Member States (AT, BE, BG, CZ, DK, 
EE, FI, FR, HR, HU, IT, LT, LU, PL, PT, SI, SK). This means that the way monitoring of non-linear audiovisual 
media service providers is  conducted, and  the methods used  to verify the data  provided do not  differ from 
methods applied to linear audiovisual service providers. 

In contrast, in seven EU Member States (BE, CY, DE, ES, NL, RO, SE), the monitoring systems of non-linear 
service providers show certain differences compared to the systems applied for linear service providers. During 
the reference period, four Member States (EL, IE, LV, MT) did not have a monitoring system in place for non-
linear audiovisual service providers. 

9 Flemish Community of Belgium. 

10 French Community of Belgium. 

11 French Community of Belgium. 

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As regards sanctions incurred by service providers when they do not comply with the AVMSD articles, these 
consist of warnings, fines and withdrawal of licence. The figure below illustrates these sanctions imposed in 
the Member States and EEA countries.  

Data reporting and application of the Commission Guidelines on the calculation of the share of 
European works in on-demand catalogues and on the definition of low audience and low turnover 

In  observing  the  data  reported  by  the  Member  States,  particularly  for  Article  13,  it  is  clear  that  this  is  a 
transitional period. Many Member States had not yet transposed the revised AVMSD. Where the laws already 
reflected the new provisions, these still had to be concretised in secondary law by regulatory authorities. In 
addition, the obligation for providers to comply with the (new) rules often only started to apply for the period 
after the reference period. In order to better indicate the current/future role of the Commission Guidelines on 
the calculation of the share of European works in on-demand catalogues and on the definition of low audience 
and low turnover12, the overview also includes changes which only took place after the reference period to the 
extent  that  this  could  be  ascertained  from  the  information  collected.  This  clearly  shows  a  high  level  of 
adherence to the calculation approaches and applications of exemptions to the Commission Guidelines. 

The market for audiovisual works 

The results of the study show that the audiovisual sector comprises approximatively 225 000 companies in 
EU27, EEA countries and the UK. The highest number of companies is in the production sector (179 000). 
Between 2019 and 2022, the audiovisual market generated around EUR 200 billion and employed around 740 
000 people. 

The analysis of the types and spread of VoD business models in the European VoD market has revealed that 
mostly  EU-owned  incumbent  players  (broadcasters,  telecom  companies  and  diversified  media  groups) 
account for half (51%) of the services in the EU27 and UK that carry recent EU27+UK film and TV productions. 
However, these incumbent players run only a quarter (28%) of the catalogues in which this content circulates. 
In contrast to this, mostly US-owned tech companies and services purely active in VoD account for less than 
a fifth of services (19%), but over a third of catalogues (35%).  

Regarding  revenue  models,  the  services  of  private  incumbent  players  compete  with  VoD-born  and  Tech 
platforms for both subscribers and advertisers, though the rollout of AVoD  in Europe is expected not to be 
parallel to the scale in the US. Small and niche VoD-players have only limited options for advertising-funding. 

The European production market is large, fragmented, characterised by small companies and infrequent output 
for  many  of  them.  An  analysis  of  levels  of  corporate  integration  reveals  that  companies  with  some  form  of 

12 Communication from the Commission Guidelines pursuant to Article 13(7) of the Audiovisual Media Services Directive on the 
calculation of the share of European works in on-demand catalogues and on the definition of low audience and low turnover 2020/C 
223/03; available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?toc=OJ%3AC%3A2020%3A223%3ATOC&uri=uriserv%3AOJ.C_.2020.223.01.0010.01.ENG 

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vertical integration, particularly with B2B rights distribution, have higher levels of circulation in more catalogues 
and countries than independent producers without integration. 

The  investments  in  European  works  by  various  players  provide  some  interesting  insights  into  recent 
developments. Most importantly, there is still significant differences between countries, ranging from funding 
requirements  established  by  media  legislation,  the  size  of  the  market,  and  the  players  active  in  content 
production and acquisition.  

Overall,  investment  in  European works has been stable  or increased in 2020-2021 across diverse players, 
from public service broadcasters (PSB) to commercial broadcasters, film funds and VoD players. COVID-19 
had a considerable impact on the audiovisual sector overall, except for investments, which were less affected.  

PSB investments remained stable in 2020-2021 and in some countries they increased. And even though public 
broadcasters might have suffered a decrease in funding, we found that this was not necessarily reflected in 
reduced investments in original programming. Furthermore, commercial broadcasters significantly increased 
their investments in original European content in 2021.  

For VoD players, investments in commissions have been growing in 2020-2021. However, genres which are 
cheaper to produce (i.e., documentary) and entertainment content (i.e., reality-TV formats) and other variety 
programming have also been on the rise.  

Independent analysis of the share of European works and independent productions in linear services 
in selected 15 MS 

To  complement  the  data  reported  by  Member  States  on  the  share  of  European  works  and  independent 
productions, Kantar Public has carried out an independent analysis of Electronic Program Guide data (EPG) 
Kantar Public scraped EPG data for over 900 linear services in 15 Member States13.  

Firstly,  the  study  analysed  the  share  of  programming  time  that  is  defined  as  qualifying  time.  The  AVMSD 
defines qualifying time as time dedicated to all programmes excluding sport events, news, games, advertising, 
teletext services and teleshopping. To identify which entries to classify as qualifying time the research team 
constructed a list of non-eligible categories and subsequently developed an automated approach that checked 
the category of each work collected over the 3-month period (November 2022 to January 2023). Across the 
captured  electronic  program  guides,  we  found  that  over  75%  of  the  programming  time  was  dedicated  to 
qualifying works out of the total amount of time broadcast. This points to the fact that the final sample of works 
based  on  which  the  analysis  was  conducted  is  very  rich,  consisting  of  a  substantial  amount  of  time.  On 
average, around 6 355 034 minutes worth of TV programmes were analysed per Member State over the 3-
month period, amounting to a total of 95 325 516 minutes. The qualifying time identified was used as a basis 
for calculating the other indicators discussed below.  

European  works  were  identified  from  the  qualifying  time  in  two  ways.  To  classify  a  work  as  European,  the 
countries of origin of the TV productions were required. This information was either present in the EPG data 
themselves or was captured by matching the titles of the works collected with the IMDb database. If the work 
was found in the online database, then the countries of origin could be retrieved too. The average share of 
European works resulting from the study research across 15 Member States is 38%, being below the share 
of European works that is reported on average by EU Member States in their own reports. There are several 
reasons for such a difference. The national reports  cover all EU27, versus only a selection of 15 countries. 
Furthermore, there are certain differences  in the definitions used between the two strands of analysis.  The 
current figure of 38% remains steady when compared to the previous one from the study conducted by Kantar 
Public in 2020-2021, when 11 Member States were analysed.  Furthermore, a significant caveat associated 
with  this  analysis  is  that  the  countries  of  origin  for  the  works  gathered  during  the  3-month  period  were 
ascertainable for approximately 30% to 50% of the total number of qualifying works.  

Relative to the other Member States covered in this analysis, Germany, Belgium, Spain and Poland particularly 
stand out with over 30 channels registering more than 50% European works. Across all the Member States, 
there  are  in  total  263  channels  (out  of  900)  with  over  50%  European  works  and  131  with  less  than  11%. 
Compared to the previous study conducted by Kantar Public in 2020-2021, the data from the current study 
shows that progress has been made and there are significantly more channels that have over 50% European 

13 The independent analysis of Electronic Program Guide (EPG) data included the following Member States: Austria, Belgium, Czechia, 
Germany, Denrmark, Estonia, Spain, France, Hungary, Italy, the Netherlands, Poland, Romania, Sweden and Slovakia.  

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works, covering more Member States than before.  

The presence of European works in prime time was analysed using as indicator the time dedicated to European 
works in prime time as share of all qualifying time.  

Germany,  Sweden  and  Belgium  registered  the  highest  percentage  of  European  works  in  prime-time  (on 
average, around 10%). On the other hand, Slovakia, Denmark and Austria dedicated the least amount of time 
to European works in prime-time (on average, less than 4%). At the channel level, taking into account the top  
five  channels  with  the  highest  market  share,  Belgium,  Germany,  Romania  and  Sweden  have  the  most 
channels with over 10% of European works in prime-time.  

The  analysis  of  the  share  of  quasi-independent  European  works  also  relied  on  an  automated  matching 
procedure with a list of independent European production companies. This implied building a list of European 
independent producers based on desk research. Subsequently, the names of the production companies of 
each work were fuzzy matched with those from the list. If a match was found, this meant that the work had at 
least one European independent production company. There are two caveats worth mentioning. Firstly, when 
constructing the list of European independent producers, the research team aimed to include most of them 
and therefore make it as comprehensive as possible. However, there are a number of sizeable independent 
producers  which  are  not  members  of  European  level  associations  which  could  not  be  included  in  the 
methodology due to timing constraints.  Therefore, this has affected the final results both at aggregate level 
and  at  individual  Member  State  level.  Compiling  the  list  of  independent  producers  is  not  possible  by  only 
conducting desk research and therefore there might be European independent production companies which 
were  missing  from  the  list.  Secondly,  although  a  fuzzy  matching  procedure  was  implemented,  European 
independent production companies might have been spelled too differently between the two databases and 
therefore  a  match  was  not  found.  Thirdly,  this  methodology  does  not  enable  to  take  account  of  works 
considered to  be  independent, even  if the production  companies  depend  on  broadcasters, as long  as they 
have been produced for an unrelated broadcaster.  

The  study  team  defined  a  European  quasi-independent  production  as  any  work  where  at  least  one  of  the 
production  companies  (in  case  of  co-productions)  could  be  matched  to  the  list  of  independent  European 
production companies. When this “quasi-independent” production definition is applied, the share ranges from 
3% in Belgium and France to 1% in Slovakia. These represent the average shares of time allotted to European 
independent  productions  at  the  Member  State  level.  In  terms  of  individual  channels,  the  majority  of  them 
exhibited  a  share  of  quasi-independent  European  works  that  fell  below  5%.  Nevertheless,  noteworthy 
disparities among channels were observed. The large channels, in terms of audience, with the highest share 
of quasi-independent productions were DR2 (Denmark – 19%), National TV (Romania – 9%), Duo 4 (Estonia 
–  6%),  Duna  TV  (Hungary  –  5%),  Italia  1  (Italy  –  5%),  ORF  1  (Austria  –  5%),  TVN  (Poland  –  5%),  Polsat 
(Poland – 4%), Nova Cinema (Czechia – 4%).  

The study also looked at the extent to which the European works broadcast are domestic, meaning at least 
one of the (co)-production countries was the same as the country where the production was being aired. The 
study found that Germany, Spain and Poland had a significant share of qualifying works where works were 
produced or co-produced by at least one company from that country (i.e, domestic works). In Germany, 61.6% 
are domestic works involving at least one German production company. In Spain, 51.5% have at least one 
Spanish production company while in Poland this was the case in 42.9% of the qualifying time.  

The linear services analysis also involved a comparison of the percentage of European works between the 
data from this study and the one reported by Member States. The analysis involved calculating the average 
difference in the percentage of European works at the channel level between the two datasets. The highest 
differences  on  the  indicator  of  European  works  were  found  for  Hungary,  Austria  and  Romania,  having  an 
average difference of over 50%. On the other hand, Spain, Germany, Italy, Poland and Sweden registered 
lower differences (an average difference of less than or around 10%). These data were also further assessed 
considering the legal context in each Member State, to better understand if having stricter processes in place 
leads to fewer differences between the data from this study and that of the Member States. The overall findings 
were that the lowest differences occurred in the Member States where there are clearer rules and processes 
on the way data is monitored and verified and where the amount of ressources allocated to these checks is 
higher. 

Independent analysis of VoD services in 21 EU Member States and Norway 

The study team used the catalogues of 1 722 VoD services across 39 countries from the dataset received by 

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JustWatch. The final sample covered all major VoD services from 21 EU Member States and Norway. These 
were the countries chosen for analysis as they are the same as those that were covered in the previous study. 
The aim was to highlight the main differences that occurred since the analysis of the previous study. The final 
sample included over 1.9 million productions. The period for which the data was analysed was February 2023. 
The Commission guidelines regarding European works and what constitutes a title were applied when counting 
series, whereby one season was considered as a single title (production).  

VoD catalogues were analysed by target market country and not by country of jurisdiction. The main reasons 
for this were: 

-  The same service provider has different catalogues by target market country. The catalogues differ 
greatly according to the characteristics of the market that is being targeted by the catalogue depending 
on the preferences of local audiences; and  

-  The dataset used was organised by target market country.  

European works represent 38% of all the catalogues analysed across all the 1 722 services listed, according 
to this analysis and 35% of the catalogues in the sample of 21 Member States and Norway. This ranges from 
27% in Hungary to 48% in France. There were no major differences between the share of European works in 
VoD catalogues that are transaction-based (TVoD) or subscription-based (SVoD). The VoD service provider 
present in multiple countries with the greatest share of European works is Mubi. It has over 50% of European 
works in all the analysed Member States and Norway. Disney Plus and Apple TV Plus, on the other hand, 
have the lowest share of European works in the dataset examined. The same VoD service providers can have 
rather different shares of European works in their catalogues depending on the targeted market countries. For 
example, Netflix has 52% of European works in Czechia, but only 35% of European works in its catalogue for 
Ireland.  The same applies  to  Amazon  Prime Video  where  over 53%  of European works  are  present in the 
Italian catalogue, while only 28% in the Irish one.  

An analysis of the country of production or co-production showed that: 

Productions with US involvement were the most frequent co-productions in all VoD catalogues for the countries 
covered. The same pattern was observed in the previous study14. Depending on the target country, the results 
from  this  study  show  that  between  35%  and  53%  of  the  co-productions  have  a  US  producer  or  partner, 
compared to 42% and 57% during 2020-2021. 

UK, France, Germany and Italy are the other major countries of (co-)production present in VoD catalogues. 
However, the presence of (co-)productions from these countries varies greatly by target market country.  

The share of domestic works in all European works varies greatly. While these represent only 1% of European 
works in Bulgaria, they are close to 60% in France. Domestic European works were defined as having at least 
one (co-)production partner from the European country that the VoD service targets (for example a French co-
production in a catalogue targeting the French market).  

The  analysis  also  shows  that  a  large  share  of  European  works  in  VoD  catalogues  in  the  EU  are  recent 
productions (released in 2017 or later). In total, we identified 989 107 European works of which 222 438 were 
considered recent European works. At the country level, most recent works were found in the VoD catalogues 
of Germany (29 127) and France (24 708) while the least were in Estonia (3 661).  

Independent analysis of prominence methods used by VoD services 

Prominence in VoD services was analysed through a mystery shopping analysed. The data collected in the 
mystery shopping exercise was then enriched with the popularity score developed by Ampere Analysis. The 
main objective was to understand if those VoD services which promote European works on their homepage 
register a higher popularity score for these works. Specifically, we aimed to gain insight into whether European 
works on the front page of VoD catalogues are more popular than non-European works, as the underlying 
assumption is that the presence of European works on the homepage represents a strong prominence method 

14 European Commission (2023). Study on the practical implementation of the provisions of the audiovisual media services directive 
concerning the promotion of European works in audiovisual media services. Available at: https://op.europa.eu/en/publication-detail/-
/publication/41f4a695-f465-11ed-a05c-01aa75ed71a1/language-en/format-PDF/source-287430951  

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that prompts titles to become more visible.  

The  study  analysed  the  main  prominence  methods  used  by  VoD  services  in  15  EU  Member  States.  This 
exercise included two main steps: 

1.  A mystery shopping which involved analysing four SVoDs offering services in 15 EU Member States 
to understand to what extent SVoD services ensure prominence of European and EU27 works. 
2.  Link the data from the mystery shopping with the popularity index developed by Ampere Analysis.  

The prominence of European works was assessed  based on  availability of  European works, advertising of 
European works, functionalities offered, visibility of European and domestic works. The results show that: 

−  40% of services include separate sections on the home page for European works and works from the 

targeted country. 

−  Among banners and advertisements in all countries, 52% are for European works, 35% are for EU27 
works, 21% are for domestic works and 16% are for UK works. The share of European works is highest 
in Sweden (85%) and lowest in Romania and Italy (both 35%). 

−  Within the functionality of the services, the study examined the existence of a ‘Recommended’ section 
an  ‘Autoplay’  function  and  a  ‘Similar’  section  under  titles.  75%  of  services  suggest  other  titles  as 
‘similar’ when selecting a title, 62% of services include a ‘Recommended’ section on the home page 
and 42% of services have an ‘Autoplay’ function (after a title is finished a new title is either suggested 
or played). The assessment of these titles allowed for an analysis of the visibility of titles. At service 
level, Voyo (61%), Mubi (67%) and local services (65%) give the highest visibility of European works.  

Conclusions  

In the period covered by the study, changes have accelerated in the audiovisual market, mainly due to COVID-
19. While VoD services were already expanding, during the COVID-19 pandemic even more people subscribed 
to these services (the number of subscribers decreased again after the pandemic). Interest in cinemas and 
linear  services  has  not  returned  to  pre-pandemic  levels.  Only  a  few  Member  States  introduced  legislative 
changes for Articles 16 and 17, which is not surprising given that the revised AVMSD did not bring any changes 
to these articles. More Member States implemented the changes brought by the revised AVMSD, in particular 
concerning Article 13, although not all Member States and EEA countries, have aligned their legislation in this 
regard yet. It shows that 2020-2021 was still an ongoing transition period due to the late transposition of the 
revised AVMSD. The independent content analysis demonstrates that the improved methodology led to more 
reliable results. On linear services, it is observed that the more resources  are allocated to the process, the 
lower the difference is between the reported figures from Member States and the finginds of the independent 
analysis.   

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Résumé 

Le présent rapport analyse la mise en œuvre de l’article 13, paragraphes 1 et 2, de l’article 16 et de l’article 17 
de la directive « Services de médias audiovisuels » (SMA) révisée15. Ces articles concernent la promotion des 
œuvres  européennes  par  les  organismes  de  radiodiffusion  télévisuelle  et  les  fournisseurs  de  services  de 
médias audiovisuels à la demande. Cette étude relève du suivi régulier imposé par la directive. Le rapport se 
réfère à la période du 1er janvier 2020 au 31 décembre 2021, et par conséquent, aux dispositions législatives 
telles qu’elles  étaient applicables  durant cet intervalle et qui sont  entrées en vigueur  en 2020. La directive 
révisée a modifié l’article 13, mais pas les articles 16 et 17.  

L’étude visait trois objectifs : 

− 

recenser les changements législatifs dans les États membres ;  

−  Fournir un éclairage sur l’évolution du marché de l’audiovisuel ; et 

−  analyser l’offre de contenu à la fois sur  la radiodiffusion télévisuelle linéaire et sur les services à la 

demande, en particulier en ce qui concerne les œuvres européennes.  

L’étude repose sur les principales sources d’informations suivantes : 

−  analyse  juridique,  par  des  juristes  indépendants  de  tous  les  pays  couverts  par  l’étude,  des  cadres 
juridiques relatifs à l’audiovisuel et de leur évolution dans les 27 États membres de l’UE ainsi qu’en 
Norvège, au Liechtenstein et en Islande ;  

−  chiffres soumis par les États membres sur la part d’œuvres européennes dans les services linéaires 

et non linéaires (à la demande) ; 

−  entretiens avec les autorités nationales pour combler les lacunes dans les informations recueillies au 

cours de la phase de recherche préliminaire ;   

−  données d’Eurostat, d’Orbis Europe, de Mavise et de la TMDB sur le secteur audiovisuel et ses sous-

secteurs ;   

−  données secondaires sur les modèles économiques dans l’audiovisuel et les investissements dans 

les œuvres européennes ; 

−  données de programmation de plus de 600 chaînes de services linéaires de 15 États membres. Pour 
ces chaînes, les données des guides électroniques de programmes (GEP) ont été recueillies pendant 
trois mois consécutifs, puis leur offre de contenus a été analysée ;  

−  catalogues  de  1 722 services  de  vidéos  à  la  demande  (VoD)  dans  26 États  membres  et  pays  non 

membres de l’UE16 ; 

−  enquêtes  « client  mystère »  sur  les  services  de  VoD  dans  15 États  membres  afin  de  recueillir  des 

informations sur les méthodes de mise en valeur utilisées ; 

−  données de la société Ampere Analylsis sur la popularité des titres ; 

15 Directive (UE) 2018/1808 du Parlement européen et du Conseil du 14 novembre 2018 modifiant la directive 2010/13/UE visant à la 
coordination de certaines dispositions législatives, réglementaires et administratives des États membres relatives à la fourniture de 
services de médias audiovisuels (directive « Services de médias audiovisuels »), compte tenu de l'évolution des réalités du marché ; 
disponible à l’adresse https://eur-lex.europa.eu/eli/dir/2018/1808/oj?locale=fr  

16 AD, AL, BA, CH, UK, IS, LI, MC, MD, MK, RS, SM, TR. 

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−  entretiens qualitatifs avec des informateurs clés au niveau de l’UE.

Le  tableau  ci-dessous  fournit  un  aperçu  des  sources  de  données  utilisées  pour  chaque  sous-section  du 
présent résumé.  

Sous-section 

Source  

Pays pris en compte 

Modifications législatives en matière de 
services linéaires  

Modifications législatives en matière de 
services à la demande  

Données de suivi sur l’application des 
articles 16 et 17 

Données de suivi sur l’application de 
l’article 13 

Analyse du marché de l’audiovisuel 

Analyse juridique indépendante 

UE27 + NO, LI et IS 

Analyse juridique indépendante 

UE27 + NO, LI et IS 

Rapports des États membres 

UE27 

Rapports des États membres  

UE27 

Recherche documentaire 
(Eurostat, Orbis Europe)* 

UE27 + UK* 

UE8** 

Modèles économiques (Mavise, 
Orbis Europe)* 

Investissements dans les œuvres 
européennes** 

Analyse indépendante de la part des 
œuvres européennes dans les services 
linéaires 

Analyse des guides électroniques 
de programmes pour plus de 
600 chaînes  

15 États membres 
sélectionnés 

Analyse indépendante des services de 
vidéos à la demande  

Analyse de 751 catalogues de 
services de VoD 

26 États membres + 
13 pays non 
membres de l’UE 

Enquêtes « client mystère » (services de 
VoD) 

Analyse de 60 catalogues de 
services de VoD  

15 États membres de 
l’UE 

Ampere Analysis  

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Modifications législatives relatives aux articles 16 et 17 en matière de services linéaires 

La directive SMA révisée n’a pas modifié les articles 16 et 17 sur la promotion des œuvres européennes et 
des œuvres de producteurs indépendants dans les services linéaires. Certains États membres de  l’UE ont 
toutefois  modifié  leur  législation  transposant  ces  deux  articles  au  cours  de  la  période  de  référence  (2020-
2021). Quatre États membres (AT, BE, EL, HR) ont ainsi adopté de nouvelles dispositions législatives durant 
cette période et deux autres (RO, SK) ont apporté de légers changements relatifs à l’article 16 après cette 
période. 

Conformément à l’article 16, tous les États membres imposent aux organismes de radiodiffusion télévisuelle 
de  réserver  à  des  œuvres  européennes  une  proportion  majoritaire  de  leur  temps  de  diffusion.  21 États 
membres (AT, BE, BG, CY, CZ, DE, DK, EL, FI, HU, IE, LU, LT, MT, NL, PL, PT, RO, SE, SI, SK) et les pays 
de l’EEE non membres de l’UE (IS, LI, NO) ont transposé les quotas exacts définis par l’UE (majorité d’œuvres 
européennes), quatre États membres ont légèrement relevé les quotas à un minimum de 51 % (EE, ES, HR, 
LV)  et  deux  États  membres  ont  fixé  un  quota  significativement  supérieur  d’au  moins  60 %  d’œuvres 
européennes (FR, IT).  

De plus, deux États membres soumettent les services publics de radiodiffusion à un quota plus élevé (BE, 
HU). Neuf États membres  appliquent par ailleurs un  quota spécifique  pour  les  œuvres produites dans leur 
langue officielle (« œuvres d’expression originale ») (EL, ES, FR, HR, HU, IT, LV, PL, PT). 

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Comme pour l’article 16, seuls quelques États membres ont apporté des modifications à l’article 17. Selon cet 
article, les États membres doivent veiller, chaque fois que cela est réalisable et par des moyens appropriés, à 
ce que les organismes de radiodiffusion télévisuelle réservent au moins 10 % de leur temps d’antenne à des 
œuvres européennes émanant de producteurs indépendants des organismes de radiodiffusion télévisuelle. 
Cinq États membres (AT, DE, FR, HR, IT) ont modifié leur législation à cet égard au cours de la période de 
référence et cinq autres (ES, HR, NL, PL, SE) ont amendé leurs lois relatives à l’article 17 de la directive SMA 
après la période de référence. 

Dans six États membres (BG, FI, HR, HU, IT, SK), les règles relatives à cette part du temps d’antenne et/ou 
du budget de programmation sont plus strictes que ce quota de 10 %. 12 États membres (BE17, CZ, ES, FI, 
HR, HU, IT18, NL, PL, PT, SI, SK) ont en outre défini des sous-quotas spécifiques pour les œuvres récentes.  

Quatre États membres (BE19, HR, HU, NL) ont fixé un sous-quota pour les œuvres d’expression originale de 
producteurs  indépendants.  Il  convient  de  souligner  qu’un  pays  de  l’EEE  non  membre  de  l’UE,  à  savoir  la 
Norvège, s’est également doté d’un sous-quota linguistique. 

Suivi et évaluation du respect des articles 13, 16 et 17 

17 Communauté française (ou Fédération Wallonie-Bruxelles). 

18 Bien que la législation d’application ait été adoptée après la période de référence en 2022. 

19 Communauté française (ou Fédération Wallonie-Bruxelles). 

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La figure ci-après illustre les systèmes mis en place par les États membres de l’UE et les pays de l’EEE non 
membres de l’UE pour contrôler si les fournisseurs de services linéaires respectent les mesures nationales 
transposant les articles 16 et 17 de la directive SMA. Cinq États membres (AT, CY, EL, HR, SE) ont adapté 
leur législation pour renforcer leurs systèmes de suivi ou de contrôle au cours de la période de référence.  

Remarque : il n’existe aucun système de suivi au Liechtenstein. 

Dix-sept États membres (AT, BE, BG, CZ, DK, EE, FI, FR, HR, HU, IT, LT, LU, PL, PT, SI, SK) recourent aux 
mêmes systèmes de suivi et de contrôle pour assurer le respect des articles 13,  16 et 17. Autrement dit, les 
méthodes utilisées pour le suivi des fournisseurs de services de médias audiovisuels non linéaires et pour le 
contrôle des données fournies sont identiques à celles utilisées pour les fournisseurs de services audiovisuels 
linéaires. 

Dans sept États membres (BE, CY, DE, ES, NL, RO, SE), par contre, les systèmes de suivi des fournisseurs 
de  services  non  linéaires  comportent  certaines  différences  par  rapport  aux  systèmes  utilisés  pour  les 
fournisseurs de services linéaires. Au cours de la période de référence, quatre États membres (EL, IE, LV, 
MT) ne possédaient pas de système de suivi pour les fournisseurs de services audiovisuels non linéaires. 

Les sanctions qu’encourent les fournisseurs de services s’ils ne respectent pas les dispositions de la directive 
SMA comprennent des avertissements, des amendes et un retrait de leur licence. La figure ci-après illustre 
les sanctions possibles dans les différents États membres et pays de l’EEE.  

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Modifications législatives relatives à l’article 13 en matière de services non linéaires 

Au total, 17 États membres (AT, BE, BG, DE, DK, EL, HR, HU, FI, FR, IT, LT, LV, LU, MT, NL, PT) ont adopté 
des mesures de mise en œuvre transposant l’article 13 de la directive SMA révisée dans leur droit interne, 
tandis que dans dix États membres de l’UE (SE, SK, SI, IE, EE, ES, CY, CZ, RO, PL) et un pays de l’EEE non 
membre  de  l’UE  (LI),  les  mesures  nationales  de  mise  en  œuvre  n’ont  pris  effet  qu’après  la  période  de 
référence. Plus précisément : 

17 États membres de l’UE (AT, BE20, BG, DE, DK, EL, FI, FR, HR, HU, IT, LT, LU, LV, MT, NL, PT) ont adopté 
des mesures nationales de transposition de l’article 13, paragraphe 1, qui imposent l’obligation, d’une part, de 
proposer une part d’au moins 30 % d’œuvres européennes dans leurs catalogues et, d’autre part, de mettre 
ces œuvres en valeur, au cours de la période de référence.  Il est important de souligner que sept de ces 
17 États (AT, BE21, FR, HR, HU, IT, MT) avaient déjà instauré des obligations similaires (en matière de quotas 
et/ou de mise en valeur) avant la révision de la directive SMA. Dans dix États membres de l’UE (CY, CZ, EE, 
ES,  IE,  PL,  RO,  SE,  SI,  SK)  et  un  pays  de  l’EEE  non  membre  de  l’UE  (LI),  les  mesures  nationales  de 
transposition ne sont entrées en vigueur qu’après la période de référence.  

La figure ci-après illustre ces changements : 

En ce qui concerne les obligations financières directes et/ou indirectes prévues à l’article 13, paragraphe 2 de 
la directive SMA, il est établi que les États membres peuvent exiger que les fournisseurs de services de médias 
(linéaires et non linéaires) relevant de leur compétence contribuent financièrement à la production d’œuvres 
européennes,  notamment  par  l’investissement  direct  dans  des  contenus  et  par  la  contribution  à  des  fonds 
nationaux.  Lorsqu’ils  imposent  de  telles  exigences,  les  États  membres  peuvent  les  étendre  aux  services 
transfrontaliers (services qui ne relèvent pas de leur compétence, mais ciblent des publics sur leur territoire), 
pour autant que ces contributions soient proportionnelles et non discriminatoires.   

Sept États membres (BE, EL, FR, HR, IT, PL, PT) ont adopté des mesures nationales de mise en œuvre au 
cours de la période de référence. 14 États membres (BG, CY, DK,  EE, FI, HU, IE, LT, LU, LV, MT, NL, RO, 
SE) et trois pays de l’EEE (IS, LI, NO) n’ont introduit aucune d’obligations financières pour la promotion des 
œuvres européennes. En revanche, 13 États membres (AT, BE, CZ, DE, ES, EL, FR, HR, IT, PL, PT, SI, SK) 
prévoient des obligations pour les services de VoD. Parmi ces 13 Membres, six (AT, CZ, DE, ES, SI, SK) n’ont 
rien  modifié  au  cours  de  la  période  de  référence,  mais  appliquaient  déjà  une  exigence  de  contribution 
financière préalablement. En parallèle, sept États membres (BE22, EL, FR, HR, IT, PL, PT) ont modifié leurs 
dispositions relatives aux contributions financières des services de VoD. Enfin, 7 États membres (BE, DE, EL, 

20 Communauté française et Communauté germanophone. 

21 Communauté  flamande  et  Communauté  française.  Dans  la  Communauté  flamande,  le  quota  était  déjà  fixé  à  30 %,  et  dans  la 
Communauté française, les services de VoD étaient déjà tenus de mettre les œuvres européennes en valeur (mais ne devaient respecter 
aucun quota précis avant la période de référence). 

22 Communauté française. 

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FR, HR, IT, PL) ont déclaré avoir étendu en vigueur les obligations de contributions financières aux services 
transfrontaliers au cours de la période de référence. 

La figure ci-après montre les États membres et les pays de l’EEE qui ont adopté des modifications législatives 
en rapport avec l’article 13, paragraphe 2, au cours de la période de référence.  

Modifications législatives relatives à l’article 13 en matière de services linéaires 

Outre les services de vidéos à la demande, l’article 13, paragraphe 2 de la directive SMA vise également les 
services linéaires. 

En 2019, il n’existait aucune règle exigeant des contributions financières directes et/ou indirectes de la part 
des fournisseurs de services linéaires dans 16 États membres : AT, BE23, BG,  CY, EE, FI, IE, IT, LU, LT, LV, 
MT,  PL, PT, RO, SI. Ces mêmes États membres n’ont instauré d’obligations financières directes ou indirectes 
pour  les  services  linéaires  ni  en  2020  ni  en  2021.  En  outre,  12 États  membres  prévoient  des  obligations 
d’investissements financiers directs ou indirects pour les fournisseurs de services audiovisuels linéaires (BE24, 
CZ,  DE,  DK,  EL,  ES,  FR,  HR,  HU,  NL,  SE,  SK).  Au  31 décembre 2021,  deux  d’entre  eux  (BE 25 ,  FR) 
appliquaient  des  obligations  de  contributions  financières  pour  les  fournisseurs  de  services  linéaires 
transfrontaliers. 

Communication de données et application des lignes directrices de la Commission concernant le 
calcul de la part des œuvres européennes dans les catalogues des services de médias audiovisuels 
à la demande et concernant la définition d’une faible audience et d’un chiffre d’affaires peu élevé 

À  l’examen  des  données  communiquées  par  les  États  membres,  notamment  pour  l’article 13,  il  apparaît 
clairement que la période de référence est une période transitoire. De nombreux États membres n’avaient pas 
encore  transposé  la  directive  SMA  révisée  à  la  fin  de  cette  période.  Dans  les  pays  où  la  législation 
correspondait déjà aux nouvelles dispositions, les autorités réglementaires ne leur avaient pas encore donné 
corps  dans  le  droit  dérivé.  De  surcroît,  l’obligation  pour  les  fournisseurs  de  services  de  respecter  les 
(nouvelles) règles n’entrait souvent en vigueur qu’après la période de référence. Afin de mieux décrire le rôle 
actuel et futur des lignes directrices de la Commission concernant le calcul de la part des œuvres européennes 
dans les catalogues des services de médias audiovisuels à la demande et concernant la définition d’une faible 
audience et d’un chiffre d’affaires peu élevé26, l’aperçu inclut également les changements qui sont intervenus 
seulement après la période de référence dans la mesure où les informations recueillies permettaient de les 
anticiper. De toute évidence, les méthodes de calcul et les dérogations définies par la Commission dans ses 
lignes directrices jouissent d’une forte adhésion. 

23 Communauté flamande. 

24 Communauté française. 

25 Communauté française. 

26 Communication de la Commission : Lignes directrices en vertu de l’article 13, paragraphe 7, de la directive « Services de médias 
audiovisuels » concernant le calcul de la part des œuvres européennes dans les catalogues des services de médias audiovisuels à la 
demande et la définition d’une faible audience et d’un chiffre d’affaires peu élevé, disponible à l’adresse https://eur-lex.europa.eu/legal-
content/FR/TXT/?toc=OJ%3AC%3A2020%3A223%3ATOC&uri=uriserv%3AOJ.C_.2020.223.01.0010.01.FRA 

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Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Le marché des œuvres audiovisuelles 

L’étude  a  révélé  que  le  secteur  audiovisuel  compte  approximativement  225 000 entreprises  dans  l’UE27, 
l’EEE et au Royaume-Uni. La plupart de ces entreprises (179 000) opèrent dans le secteur de la production. 
Entre 2019 et  2022,  le marché de l’audiovisuel  a brassé quelque  200 milliards  d’euros et employé  environ 
740 000 personnes. 

L’analyse des modèles économiques des services de VoD sur le marché européen a montré que les acteurs 
en  palce,  en  majorité  sous  propriété  européenne  (organismes  de  radiodiffusion  télévisuelle,  sociétés  de 
télécommunications  et  groupes  de  médias  diversifiés),  représentent  une  moitié  (51 %)  des  services  dans 
l’UE27 et au Royaume-Uni qui sont à l’origine des productions récentes de films et de contenus télévisuels 
dans  l’UE27  et  au  Royaume-Uni.  Ces  acteurs  traditionnels  n’exploitent  toutefois  qu’un  quart  (28 %)  des 
catalogues  dans  lesquels  ces contenus circulent.  En comparaison, les sociétés et services technologiques 
opérant exclusivement sur le marché de la VoD, en majorité sous propriété américaine, représentent moins 
d’un cinquième des services (19 %), mais plus d’un tiers des catalogues (35 %).  

Sur le front des revenus, les services des acteurs privés en place et les plateformes technologiques créées 
pour les services de VoD se font concurrence pour l’obtention d’abonnés et d’annonceurs, même si en Europe, 
le marché de l’AVoD ne connaîtra sans doute pas un déploiement comparable à celui des États-Unis. Les 
petits acteurs de niche du marché de la VoD n’ont que de minces possibilités de financement par la publicité. 

Le  marché  de  production  européen  est  grand,  fragmenté  et  est  dominé  par  de  petites  entreprises  aux 
productions irrégulières pour la plupart. L’analyse des niveaux d’intégration économique fait apparaître que 
les entreprises impliquées dans une forme d’intégration verticale, spécialement avec une distribution des droits 
en B2B, atteignent des niveaux de circulation plus élevés, dans un plus grand nombre de catalogues et de 
pays, que les producteurs indépendants non intégrés. 

Les investissements de différents acteurs dans les œuvres européennes sont instructifs quant à l’évolution 
récente.  Avant  tout,  il  subsiste  de  profondes  disparités  entre  les  pays,  notamment  dans  les  exigences  de 
financement établies par la législation sur les médias, la taille du marché et les acteurs actifs dans la production 
et l’acquisition de contenus.  

Dans l’ensemble, les investissements dans les œuvres européennes sont restés stables ou ont augmenté en 
2020 et 2021 parmi les différents acteurs, des services publics de radiodiffusion aux organismes commerciaux 
de radiodiffusion, en passant par les fonds pour les films et les opérateurs de VoD. La covid-19 a exercé une 
incidence considérable sur le secteur audiovisuel tout entier, excepté les investissements, qui ont été moins 
affectés.  

Les  investissements  des  services  publics  de  radiodiffusion  sont  restés  stables  en  2020  et  2021  et,  dans 
certains pays, ils ont même augmenté. De  plus, même si ces services publics ont subi  une  baisse de leur 
financement,  il  a  été  constaté  qu’ils  ne  l’ont  pas  nécessairement  répercutée  par  une  diminution  de  leurs 
investissements dans la programmation originale. Les radiodiffuseurs commerciaux ont en outre nettement 
rehaussé leurs investissements dans des contenus européens originaux en 2021.  

De leur côté, les opérateurs de VoD ont accru leurs investissements dans les commissions en 2020 et 2021. 
Toutefois,  les  genres  moins  coûteux  à  produire  (p. ex.  les  documentaires),  les  contenus  de  divertissement 
(p. ex.  des  émissions  de  téléréalité)  et  les  autres  programmes  de  variété  enregistrent  également  une 
progression.  

Analyse indépendante de la part des œuvres européennes et des productions indépendantes dans 
les services linéaires dans 15 États membres sélectionnés 

Afin de compléter les données communiquées par les États membres sur la part des œuvres européennes et 
des productions indépendantes, Kantar Public a mené une analyse indépendante en compilant les données 
des guides électroniques de programmes (GEP) pour plus de 900 services linéaires dans 15 États membres27.  

Tout d’abord, nous avons analysé la part du temps d’antenne éligible.  Aux termes de la directive  SMA, ce 
temps  désigne  le  temps  de  diffusion  de  l’ensemble  des  programmes,  à  l’exclusion  des  manifestations 

27 L’analyse indépendante a inclus les données des guides électroniques de programmes (GEP) des États membres suivants : 
Allemagne, Autriche, Belgique, Danemark, Espagne, Estonie, France, Hongrie, Italie, Pays-Bas, Pologne, Roumanie, Slovaquie, Suède 
et Tchéquie.  

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Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

sportives,  des  informations,  des  jeux,  de  la  publicité,  des  services  de  télétexte  et  du  téléachat.  Afin  de 
déterminer  les  entrées  relevant  du  temps  d’antenne  éligible,  l’équipe  de  recherche  a  dressé  une  liste  des 
catégories non éligibles, puis elle a élaboré un procédé automatique permettant d’attribuer une catégorie à 
chaque œuvre recensée au cours d’une période de trois mois (novembre 2022 à janvier 2023). Nous avons 
constaté que plus de 75 % du temps total de radiodiffusion était consacré à des œuvres éligibles à travers 
tous  les  guides  électroniques  de  programmes  répertoriés.  Par  conséquent,  l’échantillon  final  d’œuvres  sur 
lequel  l’analyse  est  fondée  est  extrêmement  riche  et  d’une  durée  considérable.  En  moyenne,  quelque 
6 355 034 minutes  de  programmes  télévisés  ont  été  analysées  pour  chaque  État  membre  au  cours  de  la 
période de trois mois de l’étude, soit un total de 95 325 516 minutes. Le temps d’antenne éligible identifié a 
servi de base pour calculer les autres indicateurs examinés ci-après.  

Les œuvres européennes ont été repérées de deux manières parmi le temps de diffusion éligible. Pour réaliser 
cette  classification,  il  fallait  connaître  les  pays  d’origine  des  productions  télévisées.  Soit  cette  information 
figurait parmi les données des GEP elles-mêmes, soit elle a été déduite en recherchant les correspondances 
entre les titres des œuvres recensées et la base de données IMDb. Lorsqu’une œuvre est répertoriée dans la 
base de données en ligne, son pays d’origine peut également y être consulté. À la lumière de l’étude menée 
parmi 15 États membres, la part des œuvres européennes s’élève en moyenne à 38 %, soit moins que la 
part  moyenne  communiquée  par  les  États  membres  eux-mêmes  dans  leurs  rapports.  Plusieurs  raisons 
expliquent cet écart. Les rapports nationaux sont soumis pour l’ensemble de l’UE27, contre une sélection de 
15 pays  seulement  dans  notre  étude.  En  outre,  les  définitions  utilisées  dans  les  deux  groupes  d’analyse 
diffèrent quelque peu. Le chiffre actuel de 38 % est stable par rapport à l’étude menée par Kantar Public en 
2020-2021, qui avait inclus 11 États membres. De plus, cette étude est assortie d’une réserve substantielle, 
car les pays d’origine des œuvres recensées durant la période de trois mois n’ont pu être déterminés que pour 
30 à 50 % du total des œuvres éligibles.  

Au regard des autres États membres inclus dans cette étude, l’Allemagne, la Belgique, l’Espagne et la Pologne 
se distinguent particulièrement, avec plus de 30 chaînes comptabilisant plus de 50 % d’œuvres européennes. 
À travers tous les États membres, 263 chaînes (sur 900) totalisent plus de 50 % d’œuvres européennes et 
131 chaînes moins de 11 %. En comparaison avec l’étude menée par Kantar Public en 2020-2021, il ressort 
de cette dernière étude que des progrès ont été réalisés et qu’un nombre sensiblement plus élevé de chaînes, 
dans plus d’États membres que par le passé, proposent plus de 50 % d’œuvres européennes.  

La  présence  d’œuvres  européennes  pendant  les  heures  de  grande  écoute  a  été  analysée  sur  la  base  du 
temps consacré à ces œuvres aux heures de grande écoute en proportion de l’ensemble du temps de diffusion 
éligible.  

Ce sont l’Allemagne, la Suède et la Belgique qui affichent les plus hauts taux d’œuvres européennes pendant 
les heures de grande écoute (environ 10 % en moyenne). À l’inverse, la Slovaquie, le Danemark et l’Autriche 
consacrent  le  moins  de  temps  aux  œuvres  européennes  aux  heures  de  grande  écoute  (moins  de  4 %  en 
moyenne). Au niveau des chaînes, si l’on considère les cinq principales chaînes détenant la plus grande part 
de marché, la Belgique, l’Allemagne, la Roumanie et la Suède ont le plus de chaînes dépassant 10 % d’œuvres 
européennes aux heures de grande écoute.  

La part des œuvres indépendantes a également été analysée sur la base d’une procédure automatique de 
recherche de correspondance avec une liste de sociétés de production européennes indépendantes. À cette 
fin, une liste de producteurs indépendants européens a été compilée par le biais de recherches documentaires. 
Des  correspondances,  même  partielles,  ont  ensuite  été  recherchées  entre  les  noms  des  sociétés  de 
production de chaque œuvre et cette liste. Lorsqu’une correspondance était trouvée, il était déduit que l’œuvre 
concernée comptait au moins une société de production indépendante européenne. Trois réserves méritent 
néanmoins  d’être  formulées.  Premièrement,  lors  de  la  compilation  de  la  liste  de  producteurs  indépendants 
européens,  l’équipe  de  recherche  s’est  efforcée  d’en  inclure  le  plus  grand  nombre  afin  qu’elle  soit  la  plus 
exhaustive possible. Néanmoins, un certain nombre d’importants producteurs indépendants qui ne sont pas 
membres d’associations européennes n’ont pu être inclus dans la méthodologie par manque de temps. Cela 
a donc eu un impact sur les résultats finaux, tant au niveau agrégé qu’au niveau de chaque État membre. 
Cette compilation est toutefois difficilement réalisable au moyen de recherches documentaires uniquement, et 
par conséquent, certaines sociétés de production indépendantes européennes sont peut-être absentes de la 
liste. Deuxièmement, même si les correspondances partielles ont également été recherchées, certains noms 
de sociétés de production indépendantes européennes pourraient avoir été orthographiés trop différemment 
entre  les  deux  bases  de  données,  ce  qui  explique  qu’aucune  correspondance  n’ait  été  repérée. 
Troisièmement,  cette  méthodologie  ne  permet  pas  de  prendre  en  compte  les  œuvres  considérées  comme 

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works in audiovisual media services 

indépendantes  même  si  les  sociétés  de  production  dépendent  de  radiodiffuseurs,  dès  lors  qu’elles  ont  été 
produites pour un radiodiffuseur tiers. L’équipe de l’étude a défini comme une production quasi-indépendante 
européenne  toute  œuvre  dont  au  moins  l’une  des  sociétés  de  production  (dans  le  cas  de  coproductions) 
pouvait être mise en correspondance avec la liste des sociétés de production européennes indépendantes. 
Selon  cette  définition  d’une  production  « quasi-indépendante »,  la  part  oscille  entre  3 %  en  Belgique  et  en 
France et 1 % en Slovaquie. Ces chiffres représentent la part moyenne du temps consacré aux productions 
indépendantes  européennes  au  niveau  des  États  membres.  Au  niveau  des  chaînes  individuelles,  la  part 
d’œuvres  européennes  indépendantes  est  le  plus  souvent  inférieure  à  5 %.  Néanmoins,  des  disparités 
significatives  ont  été  observées  entre  les  chaînes.  Les  grandes  chaînes,  en  termes  d’audience,  qui 
enregistrent la part la plus élevée de productions quasi-indépendantes sont DR2 (Danemark, 19 %), National 
TV (Roumanie, 9 %), Duo 4 (Estonie, 6 %), Duna TV (Hongrie, 5 %), Italia 1 (Italie, 5 %), ORF 1 (Autriche, 
5 %), TVN (Pologne, 5 %), Polsat (Pologne, 4 %) et Nova Cinema (Tchéquie, 4 %).  

L’étude s’est également intéressée à la part d’œuvres nationales parmi les œuvres européennes diffusées, 
c’est-à-dire la part d’œuvres dont au moins l’un des pays de production (ou de coproduction) était le pays dans 
lequel la production passait à l’antenne. L’étude a révélé que l’Allemagne, l’Espagne et la Pologne affichaient 
une part élevée d’œuvres éligibles produites ou coproduites par au moins une société de ce pays (en d’autres 
termes, d’œuvres nationales). En Allemagne, 61,6 % de ces œuvres européennes sont des œuvres nationales 
impliquant  au  moins  une  société  de  production  allemande.  En  Espagne,  51,5 %  émanent  d’au  moins  une 
société de production espagnole, et en Pologne, ce taux est de 42,9 %.  

L’analyse des services linéaires a en outre comparé les pourcentages d’œuvres européennes obtenus à partir 
des données de cette étude et ceux déclarés par les États membres. La différence moyenne entre ces deux 
sources de données a ainsi été calculée pour les pourcentages d’œuvres européennes au niveau des chaînes. 
C’est pour la Hongrie, l’Autriche et la Roumanie que le plus grand écart a été constaté, avec une différence 
moyenne  de  plus  de  50 %.  À  l’opposé,  la  différence  était  nettement  moindre  pour  l’Espagne,  l’Allemagne, 
l’Italie, la Pologne et la Suède (en moyenne, environ 10 % au maximum). Ces données ont été étudiées plus 
en  profondeur  à  la  lumière  du  contexte  juridique  de  chaque  État  membre  afin  de  mieux  comprendre  si 
l’existence  de  procédures  plus  sévères  réduit  les  divergences  entre  les  données  de  cette  étude  et  les 
déclarations nationales. Globalement, il est apparu que les données étaient les plus proches dans les États 
membres qui disposent de règles et de procédures plus claires sur la surveillance des données et qui allouent 
davantage de ressources à ces contrôles. 

Analyse indépendante des services de VoD dans 21 États membres de l’UE et en Norvège 

L’équipe  de  l’étude  a  analysé  les  catalogues  de  1 722 services  de  VoD  dans  39 pays  parmi  les  données 
communiquées par JustWatch. L’échantillon final portait sur les principaux services de VoD  dans 21 États 
membres de l’UE et en Norvège. Il a été décidé de retenir ces pays parce qu’ils avaient déjà été analysés 
dans  l’édition  précédente  de  l’étude,  en  2020-2021  afin  de  mettre  en  lumière  les  principaux  changements 
survenus  depuis  lors.  L’échantillon  final  comprenait  plus  de  1.9 millions  de  productions  et  la  période  pour 
laquelle les données ont été analysées est le mois de février 2023. Les lignes directrices de la Commission 
européenne sur les œuvres européennes et la définition d’un titre ont été appliquées au comptage des séries, 
une saison étant considérée comme un seul titre (une seule production).  

Les catalogues des services de VoD ont été analysés par pays de marché cible et non par pays de la juridiction 
compétente, principalement, pour les raisons suivantes : 

- 

un même fournisseur de services propose différents catalogues selon le pays du marché cible, et ces 
catalogues  diffèrent  grandement  selon  les  caractéristiques  du  marché  visé,  qui  sont  fonction  des 
préférences des publics locaux ; et  

- 

l’ensemble de données utilisé était organisé par pays de marché cible.  

D’après cette analyse, les œuvres européennes représentent 38 % des catalogues analysés sur l’ensemble 
des  1 722 services  répertoriés  et  35  %  des  catalogues  dans  l'échantillon  de  21  États  membres  et  de  la 
Norvège. Cette proportion varie de 27 % en Hongrie à 48 % en France. Il n’y a pas de différences majeures 
entre la part des œuvres européennes  dans les catalogues de VoD en paiement à la vidéo (TVoD) ou par 
abonnement  (SVoD).  Le  fournisseur  de  services  de  VoD  opérant  dans  plusieurs  pays  qui  possède  la  plus 
grande part d’œuvres européennes est Mubi, avec plus de 50 % d’œuvres européennes dans tous les États 
membres analysés et en Norvège. À l’autre extrémité du classement, Disney Plus et Apple TV Plus affichent 

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Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

la  plus  faible  part  d’œuvres  européennes  dans  l’ensemble  de  données  examiné.  Un  même  fournisseur  de 
services  de  VoD  peut  avoir  des  parts  d’œuvres  européennes  assez  différentes  dans  ses  catalogues  en 
fonction des pays du marché ciblé. Netflix compte par exemple 52 % d’œuvres européennes en Tchéquie, 
mais seulement 35 % dans son catalogue destiné à l’Irlande. Il en va de même pour Amazon Prime  Video, 
avec 53 % d’œuvres européennes dans son catalogue italien et seulement 28 % dans son catalogue irlandais.  

L’analyse du pays de production ou de coproduction a révélé ce qui suit : 

Les  productions  avec  une  participation  des  États-Unis  sont  les  coproductions  les  plus  fréquentes  dans 
l’ensemble  des  catalogues  de  VoD  des  pays  étudiés.  Le  même  schéma  avait  été  observé  dans  l’étude 
précédente28. Selon le pays cible, il s’avère aujourd’hui que 35 à 53 % des coproductions ont un producteur 
ou un partenaire américain, contre respectivement 42 % et 57 % en 2020-2021. 

Après les États-Unis, le Royaume-Uni, la France, l’Allemagne et l’Italie sont les principaux pays de production 
(ou  de  coproduction)  présents  dans  les  catalogues  de  VoD.  Cependant,  la  part  de  productions  (ou  de 
coproductions) issues de ces pays varie fortement selon le pays du marché cible.  

La  part  des  œuvres  nationales  sur  l’ensemble  des  œuvres  européennes  est  extrêmement  variable.  Ces 
œuvres ne représentent que 1 % des œuvres européennes en Bulgarie, mais près de 60 % en France. Les 
œuvres européennes étaient réputées nationales si elles avaient au moins un partenaire de production (ou de 
coproduction) implanté dans le pays européen ciblé par le service de VoD (par exemple, une coproduction 
française dans un catalogue ciblant le marché français).  

Il est également apparu qu’une part substantielle des œuvres européennes proposées dans les catalogues 
de VoD dans l’UE est constituée de productions récentes (sorties en 2017 ou plus tard). Nous avons recensé 
au total 989 107 œuvres européennes, dont 222 438 peuvent être qualifiées d’œuvres européennes récentes. 
Au niveau national, les œuvres récentes sont les plus nombreuses dans les catalogues de VoD proposés en 
Allemagne (29 127) et en France (24 708), tandis que c’est en Estonie qu’elles sont les plus rares (3 661).  

Analyse indépendante des méthodes de mise en avant utilisées par les services de VoD 

La mise en avant dans les services de VoD a été analysée au moyen d’une enquête « client mystère ». Les 
données  recueillies  par  ce  biais  ont  ensuite  été  combinées  avec  le  score  de  popularité  créé  par  Ampere 
Analysis.  L’objectif  principal  consistait  à  déterminer  si  les  services  de  VoD  qui  promeuvent  les  œuvres 
européennes  sur  leur  page  d’accueil  affichent  un  score  de  popularité  plus  élevé  pour  ces  œuvres.  En 
particulier,  nous  avons  cherché  à  découvrir  si  les  œuvres  européennes  figurant  en  première  page  des 
catalogues de VoD sont plus populaires que les œuvres non européennes, étant entendu que la présence 
d’œuvres européennes sur la page d’accueil témoigne d’une puissante méthode de mise en avant, qui confère 
une visibilité accrue à ces titres.  

L’étude a analysé les principales méthodes de mise en avant utilisées par les services de VoD dans 15 États 
membres de l’UE en deux grandes étapes : 

1.  une  enquête  « client  mystère »  dans  laquelle  quatre  services  de  SVoD  présents  dans  15 États 
membres de l’UE ont été analysés afin de déterminer la mesure dans laquelle ces services assurent 
la mise en avant des œuvres produites en Europe et dans l’UE27 ; 
la mise en relation des données de l’enquête « client mystère » et de l’indice de popularité élaboré 
par Ampere Analysis.  

2. 

La mise en avant des œuvres européennes a été évaluée d’après la disponibilité d’œuvres européennes, la 
publicité  pour  les  œuvres  européennes,  les  fonctions  offertes  et  la  visibilité  des  œuvres  européennes  et 
nationales. Les résultats sont les suivants : 

−  40 %  des  services  comprennent  des  sections  distinctes  sur  leur  page  d’accueil  pour  les  œuvres 

28 Commission européenne (2023). Study on the practical implementation of the provisions of the audiovisual media services directive 
concerning the promotion of European works in audiovisual media services (Étude sur la mise en œuvre concrète des dispositions de la 
directive relative à la fourniture de services de médias audiovisuels sur la promotion des œuvres européennes dans les services de 
médias audiovisuels, en anglais uniquement). Disponible à l’adresse https://op.europa.eu/fr/publication-detail/-/publication/41f4a695-
f465-11ed-a05c-01aa75ed71a1  

30 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

européennes et les œuvres du pays ciblé ; 

−  parmi les bannières et les publicités diffusées dans tous les pays, 52 % font la promotion d’œuvres 
européennes, 35 % d’œuvres de l’UE27, 21 % d’œuvres nationales et 16 % d’œuvres du Royaume-
Uni. La part des œuvres européennes est la plus élevée en Suède (85 %) et la plus faible en Roumanie 
et en Italie (35 % dans ces deux pays) ; 

−  dans 

le 

l’étude  a  examiné 

fonctionnement  des  services, 

la  présence  d’une  section 
« Recommandations », d’une fonction « Lecture automatique » et d’une section « Similaire » sous les 
titres. 75 % des services suggèrent d’autres titres dits « similaires » lors de la sélection d’un titre, 62 % 
ont  une  section  « Recommandations »  sur  leur  page  d’accueil  et  42 %  ont  une  fonction  « Lecture 
automatique » (à la fin d’un titre, le service suggère ou lit un nouveau titre). L’analyse de ces titres a 
permis d’apprécier leur visibilité. Au niveau des services, Voyo (61 %), Mubi (67 %) et les services 
locaux (65 %) accordent la visibilité maximale aux œuvres européennes.  

Conclusions  

Les  changements  sur  le  marché  de  l’audiovisuel  se  sont  accélérés  au  cours  de  la  période  étudiée, 
principalement  sous  l’effet  de  la  covid-19.  Les  services  de  VoD  avaient  déjà  amorcé  leur  expansion  au 
préalable,  mais  davantage  de  personnes  encore  s’y  sont  abonnées  pendant  la  pandémie  (le  nombre 
d’abonnés est redescendu après la crise sanitaire). L’intérêt pour les cinémas et les services linéaires n’a pas 
retrouvé le niveau d’avant la pandémie. Seuls quelques États membres ont modifié leur législation pour refléter 
les articles 16 et 17 de la directive SMA, ce qui n’est pas surprenant puisque ces articles sont restés inchangés 
lors de la révision de cette directive. Un plus grand nombre d’États membres ont transposé les nouveautés 
résultant de cette révision, même si la totalité des États membres et des pays de l’EEE n’ont pas encore mis 
leur législation en conformité à cet égard. Ainsi que l’illustrent les retards dans la transposition de la directive 
SMA  révisée,  les  années  2020  et  2021  faisaient  encore  partie  d’une  période  de  transition.  L’analyse 
indépendante  des  contenus  démontre  que  l’amélioration  de  la  méthodologie  a  abouti  à  des  résultats  plus 
fiables.  Pour  les  services  linéaires,  il  peut  être  constaté  que  plus  les  ressources  mobilisées  pour  cette 
procédure  sont  élevées,  moins  les  chiffres  déclarés  par  les  États  membres  s’écartent  des  conclusions  de 
l’analyse indépendante. 

31 

 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

1.  Introduction 

In 1989, the "Television without frontiers" (TVWF) Directive was adopted, triggered by economic, technological, 
cultural  and  social  transformations  in  the  audiovisual  sector.  The  expansion  of  satellite  broadcasting,  the 
spread of private TV broadcasters and the economic crisis facing the European film industry were some of the 
factors that contributed to the adoption of this Directive29. The Directive was first amended in 1997, first revised 
in 2007 to include video on demand (VoD) services in its scope. It was further revised in 2010 and consolidated 
into the Audiovisual Media Services Directive (AVMSD), and most recently revised in 2018.  

The scope and main objectives of the AVMSD are summarised below.  

Short overview  

The AVMSD  

regulates  all  audiovisual  media,  not 
only linear (traditional TV broadcasts) 
(on-demand 
but  also  non-linear 
services)  and  video-sharing  platforms  with  different 
sources: TV, internet, cable and mobile devices30.  

The latest review of AVMSD introduced two sets of guidelines 
to help MS with the implementation.  

Main objectives of the revised Directive include: 

✓  Provide rules to shape technological development  

✓  Create a level playing field for all audiovisual media players 

✓  Preserve cultural diversity 

✓  Protect children and consumers 

✓  Safeguard media pluralism 

✓  Combat racial and religious hatred  

✓  Guarantee the independence of national media regulators 

This study assesses the implementation of the provisions of the revised AVMSD concerning the promotion of 
European works in the audiovisual media services. Directive 2010/13/EU of 10 March 2010 was amended by 
Directive (EU) 2018/1808 of 14 November 2018 on the coordination of certain provisions laid down by law, 
regulation or administrative action in Member States concerning the provision of audiovisual media services 
(AVMSD)in view of changing market realities. Member States (MS) had until September 2020 to transpose the 
revised AVMSD into their national legislation.  

29 Cairn, 2017: The review of the Audiovisual Media Services Directive 

30 https://digital-strategy.ec.europa.eu/en/policies/audiovisual-and-media-services  

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Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

One important change introduced by the revised Audiovisual Media Services Directive is the reinforcement of 
the promotion of European works.  

−  The revised AVMSD introduced the reinforcement of the promotion of European works. Article 13(1) 
of  the  AVMSD  introduces  a  clear  obligation  for  on-demand  services  to  include  a  minimum  of  30% 
share of European works in their catalogues and to give them prominence. Pursuant to Article 13(2) 
of the AVMSD, Member States can extend the financial contributions to the production of European 
works  (direct  investments  in  content  or  contributions  to  national  funds)  that  may  imposedon  media 
service providers under their jurisdiction to media service providers established in another Member 
State that target audiences in their territories, as long as the measures are proportionate and non-
discriminatory  and  compliant  with  EU  law.  Media  service  providers  with  a  low  turnover  or  a  low 
audience are exempted from these obligations. 

−  The revised AVMSD leaves unchanged the obligations concerning the promotion of European works 
by linear services. Article 16 stipulates that “Member States shall ensure, where practicable and by 
appropriate  means,  that  broadcasters  reserve  for  European  works  a  majority  proportion  of  their 
transmission  time,  excluding  the  time  allotted  to  news,  sports  events,  games,  advertising,  teletext 
services  and  teleshopping.  This  proportion,  having  regard  to  the  broadcaster’s  informational, 
educational,  cultural  and  entertainment  responsibilities  to  its  viewing  public,  should  be  achieved 
progressively, on the basis of suitable criteria (…).” 

−  The revised AVMSD also leaves unchanged the obligations concerning the promotion of European 
works by linear services. Article 17 stipulates that “Member States shall ensure, where practicable and 
by appropriate means, that broadcasters reserve at least 10% of their transmission time, excluding 
the time allotted to  news,  sports events,  games,  advertising, teletext services  and teleshopping,  or 
alternately,  at  the  discretion  of  the  Member  State,  at  least  10%  of  their  programming  budget,  for 
European works created by producers that are independent of broadcasters. This proportion, having 
regard to the broadcaster’s informational, educational, cultural and entertainment responsibilities to its 
viewing public, should be achieved progressively, on the basis of suitable criteria. It must be achieved 
by earmarking an adequate proportion for recent works, that is to say works transmitted within 5 years 
of their production (…).” 

The aim of this study is to provide the European Commission (DG CONNECT) with the information required 
for their efforts to monitor and evaluate at periodical intervals (as foreseen by the AVMSD) the impact of the 
aforementioned  articles  that  aim  at  improving  the  promotion  of  European  works,  including  independent 
productions in television programmes and on-demand services. Additionally, the study aims to contribute to a 
better understanding of the AVMSD impact on cultural diversity taking into account the development of the 
audiovisual market.  

The study covers all EU Member States, and the relevant time period is from 1 January 2020 to 31 December 
2021. 

The study has three main parts: 

−  Volume 1 assesses the implementation of Articles 13, 16 and 17 of the AVMSD 

−  Volume 2 assesses the market for audiovisual works 

−  Volume 3 analyses the content offer of linear and non-linear services  

33 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

2.  Study methodology 

2.1     Task 1 – Legal research 

After an inception phase, in which the study team refined the methodology for Task 1 and developed guidelines 
and the country fiche template for national legal researchers, the legal research in all EU Member States and 
the EEA countries was launched in early August 2022 over a period of six weeks. The legal mapping exercise 
was carried out by our team of national legal researchers, including legal experts from the Institute of European 
Media Law (EMR).  

The  national  legal  research  was  a  combination  of  legal  desk  research  and  interviews  with  relevant 
stakeholders 31 .  Our  team  of  national  legal  researchers  conducted  interviews  with  National  Media 
Regulatory  Authorities  (NRAs)  on  the  implementation  of  the  Directive  and  the  associated  monitoring 
mechanisms  under  Articles  13,  16  and  17  in  each  country.  These  interviews  aimed  to  collect  additional 
qualitative and quantitative information and to fill in any data gaps on existing monitoring mechanisms in each 
country.  

The  data  collected  includes  all  implementing  measures  of  Articles  13(1),  13(2),  16  and  17  of  the  revised 
AVMSD, as well  as information on the impact  of the  application of the Guidelines on the calculation of  the 
share of European works in on-demand catalogues on the promotion of European works in all EU Member 
States and EEA countries in the period from 1 January 2020 to 31 December 2021. National implementing 
measures  were  compared  with  the  situation  in  2019  (baseline  scenario).  For  the  countries  which  had  not 
transposed the revised AVMSD at the time of the research, national researchers were asked to consult the 
most  recently  updated  version  of  the  existing  relevant  draft  legislation  accessible  from  the  website  of  their 
respective legislative bodies. 

The output of this Task was 30 national reports (EU27 and EEA countries), which are  annexed to this 
report.  

2.2     Task 1 – Member States reporting  

In parallel to the national legal research, our research team worked with the legal experts from the Institute of 
European Media Law (EMR) to develop templates for the national reports, to be completed by the EU Member 
States under Articles 13(4) and 16(3) of the AVMSD on the application of Articles 13(1), 13(2), 16 and 17. After 
approval of the template by the Commission, in November/December 2022 our research team reached out to 
all the EU Member States and EEA countries for the purpose of filling in the templates for the national data 
reports that EU Member States are expected to submit to the Commission in light of their reporting obligations 
pursuant to Articles 13(4) and 16(3) of the AVMSD. Each national report template was pre-filled with a list of 
services established for that Member State, on the basis of the data available on the MAVISE database of the 
European  Audiovisual  Observatory,  and  detailed  explanations  and  instructions  were  provided  for  the 
completion of the national report template.  

In addition, EU Member States and EEA countries were asked to review, clarify if necessary and validate the 
content of the country fiche filled in by our national legal researchers as a result of the legal mapping.  

For this report, the national data monitoring reports of all the Member States and non-EU EEA countries were 
collected. Some limitations are detailed in section 3.4   Thirteen country fiches presented in this report were 
validated (AT, BG, CY, CZ, EE, LI, LT, LU, LV, NO, PT, SE and SK) while comments were received concerning 
17 country fiches (BE, DE, DK, EL, ES, FI, FR, HU, HR, IE, IS, IT, MT, NL, PL, RO and SI).  

All national reports collected are annexed to this Final Report. 

31 Please refer to the Inception Report for the full list of stakeholders consulted by the national legal researchers. 

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Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

2.3     Task 2 – Desk research and interviews  

Volume 2 presents the latest trends in the audiovisual sector during the reference period, by looking at the 
size of the market, business models and investments in European works.  

Some of  the research questions laid out in the inception report could  not  be  answered for reasons of  data 
availability. For example, there were some limitations on the assessment of the audiovisual market owing to 
Eurostat data not being published in the reference period. As an alternative, Orbis Europe data was used to 
determine the number of companies, employee count and revenues (although for the latter two aspects, not 
all companies reported this data). Furthermore, the data source did not have data about the country of origin 
of the companies available in Europe and this could not be determined through other sources. 

Regarding the assessment of business models, limitations were  identified, and mitigation measures applied 
as follows: 

−  The  prevalence  of  business  models  in  production  could  only  be  analysed  for  143  top  producers, 
because  no  data  on  ownership  and  integration  could  be  derived  from  Orbis.  Therefore,  manual 
research from a range of qualitative sources had to be carried out, which was not feasible for a larger 
sample. Instead, an analysis of producer company sizes and their effects on the circulation of content 
was carried out for a sample of 1 477 companies. 

−  Because the detailed analysis of production business models could only be carried out for the 143 top 
producers, no analysis of the prevalence and spread of these business models within the EU (including 
comparison with the UK) could be carried out. Instead, a comparison of the prevalence of company 
sizes in the dataset  of 1 477 companies was carried  out, with the focus on a comparison between 
countries with different production capacities.  

−  Because the data on revenues and employees that could be retrieved from Orbis was too limited (only 
available for 5% of companies), it was not considered in the analysis of business models. Instead, the 
Orbis  indicator  of  company  size  available  for  1  477  companies  was  used,  which  takes  revenues, 
assets and employees into account. 

−  Content budgets retrieved from TMDB were not used in the analysis because of their limited availability 

and because of a lack of transparency regarding how the budgets were estimated. 

−  Dimensions of genre and form (TV/film) have not been systematically assessed because the genre 
data from TMDB proved complicated to handle in a systematic way, since TMDB offers 26 different 
genres and up to three genre categories per title. Instead of using time to make the genre knowledge 
workable,  more  time  was  invested  in  maximising  the  number  of  production  companies  for  which 
production size data from Orbis could be used. 

Regarding the investment in European Works, limitations were identified, and mitigation measures applied as 
follows: 

−  The chapter focuses mainly on the main developments with regard to the financial contributions by TV 

broadcasters and on-demand services in European works. 

−  Eight EU in-depth case studies were carried out. As it was not possible to find reliable data across 
multiple countries on investments, we needed to base the analysis of different indicators on in-depth 
desk research and stakeholder consultation.  

− 

It was not possible to make a distinction between some of the indicators in each country analysed due 
to the way in which data is reported in each country and limited data accessibility. 

−  The analysis refers to 2020-2021 data. 

− 

It was not possible to analyse the return on investment. 

−  We  adjusted  our  sources  according  to  our  findings  as  the  research  progressed,  e.g.,  we  added 

Lumiere database to our analyses, but did not use EBU reports as previously indicated. 

Size of the European audiovisual sector 

In this regard, the team mapped the producers and distribution landscape based on size and geography. One 
of the main challenges of this mapping was that Eurostat and EAO data are not readily available for the study’s 

35 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

reference  period  (data  is  only  available  for  2018  and  2020).  Thus,  any  data  related  to  the  revenues  and 
employee count of companies was extracted from Orbis Europe (by NACE code).  

The main NACE codes for which our team extracted data are: 

−  J59.1.1 - Motion picture, video and television programme production activities 

−  J59.1.2 - Motion picture, video and television programme post-production activities 

−  J59.1.3 - Motion picture, video and television programme distribution activities 

−  J60.2 - Television programming and broadcasting activities. 

This report provides data for the following metrics: number of active companies, employee count and revenues. 
It is to be noted that only active companies available on Orbis Europe were included in the analysis.  

Business models in the audiovisual sector 

The analysis of business models in VoD distribution seeks to investigate how ownership, revenue models and 
geographical footprint are combined into different business models of VoD services and how widespread these 
models are in the EU’s market.  

The dataset used as the basis for the analysis of business models in the EU’s audiovisual distribution is derived 
from  the  EAO’s  Lumiere  VoD  database,32 automatically  and  manually  enriched  with  data  from  the  Mavise 
database,33 industry press and corporate websites. The Lumiere VoD dataset used as a basis for this analysis 
consists of 4 769 unique film titles and 2 626 TV seasons produced or co-produced in an EU27 country + the 
UK in 2020 and 2021, which were distributed in one or more of 840 VoD catalogues from 23 countries surveyed 
by the EAO as of April 2022 (Table 1). The number of catalogues represents a sample of 50% of the 1 684 
TVoD, SVoD and FVoD services listed in the Mavise database for these 23 countries as of 31 August 2022. 
Services which have no film or TV productions from the EU27+UK produced in 2020/21 in their catalogues 
have been excluded from the analysis, because platforms without recent EU27+UK titles are not considered 
relevant for the European production-business, which is the focus of the second part of this analysis (section 
4.2.2   )  

Table 1 Number of catalogues in the Lumiere VoD dataset used as the basis for the business model 
analysis 

Country 

Number of catalogues in 
dataset 

AT 

BE 

CH 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GB 

HU 

IE 

IT 

LT 

46 

31 

42 

38 

65 

37 

22 

42 

40 

48 

68 

24 

33 

40 

23 

32 https://lumiereVoD.obs.coe.int/ 

33 http://mavise.obs.coe.int/ 

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Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country 

Number of catalogues in 
dataset 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

TR 

22 

42 

38 

29 

28 

18 

42 

22 

SUM 

840 

To investigate business models in VoD distribution, the 840 catalogues have been manually consolidated to 
174  unique  VoD  services  and  23  Amazon  channels. 34 The  EAO’s  Mavise  database  was  used  to  deepen 
knowledge of the services in terms of their geographical footprint and corporate ownership. Not all catalogues 
available in the Lumiere VoD database are reflected in the Mavise database.35 For services not recorded in 
the Mavise database, information from within the Lumiere VoD dataset and additional research on corporate 
websites and industry sources (Digital TV Europe, Broadband News and Variety) were used to determine the 
geographical footprint and corporate ownership. The business information on corporate owners, locations of 
headquarters, geographical footprint and revenue models of the 174 distinct VoD services (840 catalogues) 
were  then  used  as  the  basis  for  distinguishing  business  models  of  streaming  services  active  as  buyers  of 
content in the European market. For the sake of clarity, the services have been coded as belonging to one of 
nine models, although overlaps between different categories exist. 

The analysis of business models in production examines prevalent business models in the production 
of film and televisual content with a focus on the ownership and integration of companies along the 
value  chain  and  assesses  how  they  correlate  with  different  VoD  business  models  and  distribution 
patterns. Following Doyle et al.’s 2021 study of the British production sector36 business models in production 
are assessed based on company sizes, ownership, vertical integration along the value chain, types of products 
and patterns of product circulation. 

The basis for this analysis  is the  Lumiere dataset  of 2020/2021 of  7 395 film and TV  productions from the 
EU27+UK  made  available  for  VoD  distribution.  The  production  business  model  analysis  therefore  covers 
companies from EU27+UK which produced or co-produced film or television titles in 2020 or 2021, which were 
distributed via VoD in one or several of 19 EU markets plus CH, NO, TR, UK. In contrast to the EAO’s focus 
on TV fiction,37 the dataset used for this study also includes cinematic film, documentary and other forms 38 of 
TV (co-)production. The data has been further enriched using The Movie Database (TMDB) and Orbis. The 
scraping of the TMDB database generated names of producing and/or co-producing companies for 37% of the 
film  titles  and  TV  seasons  from  the  Lumiere  VoD  dataset  (considering  first  to  fifth  producer).  The  TMDB 
scraping yielded a list of 3 668 names of producers.  

34 The Amazon channels are excluded from the analysis because they are in most cases simply a different distribution path for services 
existing outside the Amazon infrastructure (e.g. the Amazon Britbox channel and Britbox VoD service). 

35Some of the data in the Mavise database does not reflect current availability or ownership structures as some services have changed 
names (e.g. TV Now > RTL+) and mergers have taken place (e.g. the merger of Discovery and Warner Brothers). For those services 
recorded in the Mavise database, the ownership information given there is the basis for analysis. For services not recorded in the 
Mavise database ownership information as available through industry sources and corporate communication by 1 November 2022 has 
been used. 

36 Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the 
digital challenge. Basingstoke: Palgrave Macmillan.  

37 Fontaine, Gilles (2022): Audiovisual fiction production in Europe. 2020 Figures. Available online at https://rm.coe.int/audiovisual-
fiction-production-in-europe-2020-figures/1680a5d715.  

38 Reality programmes (e.g. First Dates, All4 UK/IE), Comedy shows (e.g. Last one Laughing, Amazon Prime DE), Talk shows (e.g. 
Programa Cautelar, RTP Play PT), Music (e.g. Agents Are Forever - The Danish Radio Symphony Orchestra, iTunes) 

37 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

The list of producers generated through the TMDB scraping has been further enriched using Orbis. Combining 
the knowledge on company location from TMDB and Orbis, 1 897 companies could be identified as located in 
an EU27 country or the UK. Of these companies, 1 477 could be characterised further according to company 
size using data from Orbis. Figure 1 shows the availability of data per country.  

Figure 1: Number of companies per country for which data from TMDB and Orbis is available 

500

450

400

350

300

250

200

150

100

50

0

T
A

E
B

*
G
B

*
Y
C

Z
C

E
D

K
D

E
E

S
E

I
F

R
F

B
G

*
R
G

*
R
H

U
H

E
I

T
I

T
L

V
L

*
U
L

*
T
M

L
N

L
P

T
P

O
R

E
S

*
I
S

*
K
S

Companies with TMDB-ID

Companies with Orbis ID

Data from the countries with an asterisk is limited because the Lumiere VoD database (see Table 1 Number 
of catalogues in the Lumiere VoD dataset used as the basis for the business model analysis) did not contain 
catalogues  for  these  countries,  which  makes  it  likely  that  significant  local  film  and  TV  (co-)productions  for 
2020/21 and therefore significant local producers may not be present in the dataset.  

The 1 477 EU27+UK  producers for which Orbis IDs were available could  be further classified according to 
company  size.  Orbis  assesses  company  size  “based  on  operating  revenue,  total  assets  and  employees” 
distinguishing  between  small,  medium,  large  and  very  large  companies.  Concrete  employee  numbers  and 
revenue data were, however, only available for 5% of the companies. Further qualitative indicators, namely 
‘main business line’ and ‘main products or services’ were available for 24% of companies reaching 90% to 
100% for the large to very large companies. Because of their limited availability, the financial indicators from 
Orbis were not used in the further analysis. 

Data on company ownership and level of integration could not be retrieved from Orbis. Therefore, a manual 
assessment  of  ownership  and  the  level  of  integration  along  the  value  chain  has  been  carried  out  for  143 
companies that have (co-)produced five or more titles in circulation in at least one of the 840 catalogues from 
the  Lumiere  VoD  dataset.  The  sample  covers  producers  placed  in  18  countries 39 and  accounting  for  the 
production of 903 film and TV titles (fiction & non-fiction) in 2020/2021. 

Ownership and levels of integration were assessed using the following indicators: 

−  available TMDB data on number of 2020/21 productions in VoD circulation, type of production (film, 

TV) and genre; 

−  available Orbis  data on  main business lines and main products/services (mostly  available for large 

and very large companies), corporate websites; 

−  corporate owners, the location of their corporate owners, the geographical footprint of their activities 
and their level of integration along the value chain, i.e., whether production companies themselves or 
their corporate owner own distribution companies, broadcasters, streaming services or cinemas using 
corporate websites, annual reports and industry press (e.g., Digital TV Europe, Variety and Cinando).  

39 AT (1), BE (7), CZ (5), DE (22), DK (4), ES (7), FI (3), FR (25), GB (25), GR (1), HU (1), IE (1), IT (29), NL (2), PL (2), PT (1), SE (4), 
SK (1). 

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

For the purpose of this study, the level of vertical integration of European AV producers focuses on three 
stages in the value chain:  

−  The  production  stage  goes  from  the  creative  and  financial  development  of  projects  up  to  the 
completion of the actual audiovisual production. This stage, naturally, requires additional supplies such 
as studio space or  provision of technology. For the  purpose  of this study, these are not taken into 
account. 

−  The  B2B  Distribution/Rights  trade  is  concerned  with  marketing  and  bringing  (largely)  finished 
audiovisual products to content different aggregators (broadcast, cable, pay-TV), exhibitors (cinemas) 
or physical media. This step encompasses the domestic and international sale of rights. 

−  Distribution to consumers encompasses the packaging of AV content into broadcast programmes, 
channels or VoD catalogues, their cinematic showing or sale as physical copied. The element of the 
technological  infrastructure  involved  in  the  digital  distribution  is  disregarded  for  the  purpose  of  this 
study. 

Based on the information about ownership, vertical integration, main business lines and products of the 143 
companies, as well as knowledge about the circulation of their content from the Lumiere VoD dataset, seven 
business models in production were distinguished. The limitations of the methodology used to determine the 
business models in production are discussed together with the findings in section 4.2   . 

Investment in European works and the rights market 

The analysis is conducted for the following eight EU countries: Belgium, Czechia, Germany, France, Italy, the 
Netherlands,  Poland,  and  Sweden.  The  case  selection  aims  to  achieve  geographic  diversity,  as  well  as 
covering  small  and  large  media  markets.  The  data  applies  a  mixed-methods  approach:  case  study  set-up, 
desk research, and consultations with local media market experts and representatives of audiovisual funds in 
the EU to fill data gaps (see table below). 

Consultation with 

Data consultation 

Applicable countries 

Contacted 

European Film agencies Directors (EFAD) 

Levies to be paid to funds 

EU8 

Nov. 2022 

Flanders Audiovisual Fund (VAF) 

Levies to be paid to funds 

Belgium (FL) 

Dec. 2022 

Prof Dr Michal Glowacki (University of 
Warsaw) 

Prof Dr Petr Szczepanik (Charles 
University, Prague) 

PSB investments 

Poland 

Jan. 2023 

PSB investments 

Czechia 

Feb. 2023 

Stakeholder interviews (EU organisations)  

Several interviews with EU-level organisations representing different stakeholders from the audiovisual market 
were carried out for Task 2. Some results of the interviews also fed into Task 1. The following organisations 
were interviewed.  

Table 2: Stakeholders interviewed  
Name  
European Broadcasting Union  

Network of European Independent VoD Platforms 
(EUROVOD)  
European Film Agency Directors association (EFAD)  
Eurocinema  
The Association of Commercial Television in Europe (ACT)  
European Film Promotion  
European Producers Club  
European VOD coalition  

Type  
Non-linear and linear media 
providers  
Non-linear media providers  

Production  
Production and distribution  
Linear broadcasters and VoD services  
Distribution  
Production  
Non-linear media providers  

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ACE Producers  
European Audiovisual Production association (CEPI)  
Society of Audiovisual Authors (SAA)  
Federation of European Screen Directors (FERA)  

Production  
Production  
Production  
Production  

2.4     Task 3 – Analysis of the audiovisual content offer 

Task 3 aims to understand the content available on the audiovisual market by analysing programming guides, 
video on-demand catalogues, and prominence methods of video on-demand services. 

2.4.1     Analysis of electronic programming guides (linear services) 

In order to carry out an independent assessment of the share of European works in linear services we have 
web-scraped  electronic  programming  guides  in  15  selected  Member  States  over  a  three-month  period  (1 
November 2022 to 31 January 2023). In total, data for more than 900 eligible channels were analysed covering 
over 1.5 million entries, where one entry represents an eligible production.  

The 15 Member States selected for this analysis were: Austria, Czechia,  Estonia, Germany, Spain, France, 
Hungary,  Italy,  Netherlands,  Poland,  Romania,  Sweden,  Slovakia,  Belgium  and  Denmark.  These  Member 
States were selected as representing: 

−  The largest audiovisual markets in the EU while also covering diversity between medium-sized and 

large markets; 

−  Diversity in terms of regions of the EU; and  

−  Diversity in terms of market fragmentation. 

Section 5.1 provides a detailed summary of the methodology and the dataset analysed, as well as the way in 
which indicators were computed. 

2.4.2     Analysis of video-on-demand catalogues 

To carry out the analysis of video-on-demand catalogues, we have worked together with JustWatch, which is 
the aggregator with highest number of catalogues.  

We  included  in this  analysis 1 046  VoD services across 22 target countries were included  in this analysis, 
since these services were analysed by target country and not country of jurisdiction. Target country means the 
country the audience of which is targeted by the VoD service. This approach was agreed because ultimately 
audiences are exposed to European works in the target countries and not in the countries of jurisdiction. The 
target countries were therefore a relevant unit of analysis in understanding exposure of audiences to European 
works distributed through VoD.  

Section 5.2 gives further information on the methodology and the sample of services and content analysed. 

2.4.3     Analysis of prominence methods on video-on-demand services (mystery shopping) 

The  main  objective  of  this  activity  is  to  assess  the  methods  SVoD  services  use  to  ensure  prominence  of 
European and EU27 works and the way these prominence methods impact on the European works’ audience 
demand.  

To this aim, two analyses were planned. Firstly, a mystery shopping exercise which involves analysing four 
SVoDs for 15 EU Member States to understand to what extent SVoD services ensure visibility of European 
and EU27 works. Secondly, the data collected through the mystery shopping exercise would subsequently be 
linked to the popularity index developed by Ampere Analysis.  

This  section  presents  a  detailed  explanation  of  the  methodological  approach  for  conducting  the  mystery 
shopping, including: 

−  The overall rationale for opting for a mystery shopping analysis; 

−  The indicators chosen for the analysis; 

−  The platforms selected; 

−  The set-up process that led to the collection of information;  

−  The analysis of the data collected into high-quality results. 

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1.  The overall rationale for a mystery shopping analysis 

Very limited data is available regarding the way SVoD services design their platforms to ensure prominence 
of  European  and  EU27  works,  especially  with  a  multi-country  scope.  As  such,  a  method  to  capture  the 
complicated body of data required was implemented. A mystery shopping technique was most suitable for the 
needs of this study as it allowed for the recreation of the experience that the users see and allowed for the 
inspection of both the content offer of these catalogues and the structure of the SVoD’s homepages that play 
an  important  role  in  ensuring  visibility  of  certain  works.  Moreover,  this  method  also  ensured  that  the  data 
collectors  (hereafter  the  ‘mystery  shoppers’)  could  take  note  and  record  certain  platform-specific 
characteristics.  Thus,  as  a  result,  data  collected  could  be  analysed  via  both  a  quantitative  approach  (e.g., 
calculating  percentages  and  indicators  for  prominence)  and  a  qualitative  assessment  (i.e.,  considering  the 
content of the mystery shoppers’ notes). Generally, by recreating the experience the audience sees, it is most 
suitable to address the specifics of the platform and to answer the data needs. 

2. 

Indicators selected 

Prominence is a multidimensional concept and thus there are many ways prominence can appear and how it 
can be measured. As such, multiple factors of prominence were considered, and indicators were designed for 
each of these factors. 

The  first  step  in  conducting  the  mystery  shopping  involved  identifying  the  main  prominence  measures  that 
platforms use or could implement with the aim of promoting European and EU27 works: since these indicators 
are  the  core  variables  required  to  achieve  the  aim  of  the  analysis,  the  design  of  the  method  had  as  goal 
identifying the optimal way in which we could obtain the most reliable information on them.   

As a first step, the Kantar team reviewed the literature and recorded the main prominence methods that could 
be  analysed.  Moreover,  these  methods  were  subsequently  checked  by  Kantar’s  partners  from  SMIT  who 
provided feedback and proposed additional points for the analysis.  

The following was the final list used: 

Table 3: Exhaustive list of prominence methods tested in the mystery shopping 

Definition 

Proposed indicator 

Prominence 
measure 

Prominence on 
front page 

Advertising within 
the service 

The algorithmic promotion of 
European and EU27 works/ 
works from the targeted 
country on the front page of 
the service 

The promotion of European 
and EU27 works/ works from 
the targeted country within 
the service through for 
example, banners and 
posters 

Prominence 
factor 

Visibility 

Presence/share of European 
or EU27 works/ works from 
the targeted country on the 
front page 

The existence of banners or 
posters promoting European 
or EU27 works/ works from 
the targeted country 

Advertising 

Dedicated section  A dedicated section/area for 
European and EU27 works/ 
works from the targeted 
country that can be as easily 
accessible as possible 

Availability 

A dedicated section for 
European or EU27 works/ 
works from the targeted 
country at on the front page of 
the service or on another 
page 

Filtering for 
European works/ 
works from the 
targeted country 

The ability for a user to filter 
content and find a collection 
of European works/ works 
from the targeted country 

The ability to select the genre 
‘European’/ targeted country 
or other ways to filter content 

Availability 

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Prominence 
measure 

Definition 

Proposed indicator 

Searching for 
European works/ 
works from the 
targeted country 

The ability for a user to 
directly/explicitly search for 
European works/ works from 
the targeted country 

The ability to use the search 
function to find European 
works/ works from the 
targeted country 

Prominence 
factor 

Availability 

Labelling of 
European works 

The existence of a label that 
is attached to all European 
works that indicates that the 
content is European 

Categorization of 
European or EU27 
works 

The existence of pre-set 
categories of content based 
on origin of titles 

The existence of ‘European’ 
labels on European works 

Availability 

Availability 

Assessment of what type of 
categories are found on the 
homepage and whether the 
categories cover specific 
countries, broad regions or 
none 

Prominence in 
similar content 

The algorithmic promotion of 
European and EU27 works/ 
works from the targeted 
country in ‘similar’ content 

Presence/share of European 
and EU27 works/ works from 
the targeted country when 
suggesting ‘similar’ content 

Functionality 

Prominence in 
recommendations 

The algorithmic promotion of 
European and EU27 works/ 
works from the targeted 
country in the user’s 
‘Recommended’ section of 
the service 

Prominence in the 
content the user 
watches 

The algorithmic promotion via 
the ‘autoplay’ function 

Prominence in 
search 
recommendations 

The algorithmic promotion of 
European and EU27 works/ 
works from the targeted 
country in search 
recommendations  

Presence/share of European 
and EU27 works/ works from 
the targeted country in 
‘Recommended’ section 

Functionality 

Presence/share of European 
and EU27 works/ works from 
the targeted country 
presented using the ‘autoplay 
function’ 

Presence/share of European 
and EU27 works/ works from 
the targeted country in search 
recommendations 

Functionality 

Functionality 

The  final  prominence  dimensions  in  the  table  above  were  divided  into  four  main  factors  that  ensured  the 
services  were  analysed  through  multiple  lenses  in  line  with  the  scope  of  the  study,  thus  achieving  a 
comprehensive assessment of the techniques used to promote European and EU27 works: 

−  Visibility: the purpose of this factor was to understand the extent to which European and EU27 works 
were present on the homepage of the services. The homepage of a SVoD service is considered the 
most visible page and the place where users spend most of the time. Thus, it was important to record 
the total number of European works and EU27 works/ works from the targeted country as opposed to 
the total number of non-European works.  

For this indicator, the first 10 titles from the first 10 sections of the homepage were written down.  

Importantly, this first part was conducted before interacting with the service in any way. This ensured 
that  the  homepages  contained  the  titles  that  users  can  find  without  the  intervention  of  the  Artificial 
Intelligence/ Machine learning algorithms. 

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−  Advertising: the purpose of this section was to investigate if the service used any advertising spots on 
the homepage to specifically promote European and EU27 works/ works from the targeted country. In 
this respect, mystery shoppers looked for specific banners or ads and subsequently wrote down the 
names of all the works being promoted. The data will then be analysed to calculate what percentage 
of the advertising spots were allocated to European and EU27 works/ works from the targeted country.  

Moreover, mystery shoppers noted if any unusual ways of showing the advertising spots were present 
or if they were not visible enough.  

−  Availability: the purpose of this section was to identify if the services designed their platform in a way 
that allowed the  users to quickly find European and  EU27 works/ works from the targeted country. 
This would entail the  users being able to search for European and EU27 works directly, find these 
works in a dedicated section on the homepage, filter content based on genre, hover over titles and 
find a label indicating the origin of the work or any other similar features.  

−  Functionality:  finally,  the  purpose  of  this  last  factor  was  to  gain  insight  into  the  types  of  works  the 
platforms recommend once the user interacted with their content. Thus, mystery shoppers were asked 
to  add  titles  to  their  watchlist  and  then  check  the  ‘similar’  and  ‘recommended’  sections  on  the 
homepage. They also explored the possibility of having European works and EU27 works promoted 
via the ‘autoplay’ function. The data would then lead to calculating the share of European works and 
EU27 works/ works from the targeted country which are specifically suggested by the service.  

As part of the mystery shopping, two main profiles were used for the creation of ‘users’ on the services which 
were used for inspecting the catalogues of the SVoD services. When signing up to the service, the ‘mystery 
shoppers’ used one of the two profiles to create the user. The two profiles had different characteristics in terms 
of age and gender. One of the two profiles were allocated to each country, at random. The mystery shoppers 
then used the same profile for the platforms analysed in the same country and therefore the results from the 
indicators described above held constant the user’s socio-demographic characteristics. This way, the results 
would not be biased by the services’ AI algorithm showing different works based on those socio-demographic 
characteristics.  

The exact description of each profile will be shown in the next sections. 

3.  The platforms selected 

The aim of the analysis is to understand to what extent SVoDs that are frequently accessed by EU citizens 
use any prominence strategies and what are the strategies’ impact on the popularity index. Thus, the sample 
had to be composed of services that are most used in that country and hence whose strategies would impact 
a high number of people. 

Once the final list of prominence methods was agreed, the next step consisted  of selecting the appropriate 
SVoD platforms for each of EU Member State. In total, 4 SVoD platforms were to be selected per EU Member 
State. 

The criteria for the selection of SVoD platforms were chosen with the aim of selecting SVoDs for each country 
that satisfy three conditions: 

A.  The final SVoDs chosen have large audiences in the country where they are available 
B.  The  final  SVoDs  represent  a  mixture  of  catalogues  in  terms  of  the  percentage  of  European  works 
available, meaning that the sample consists of both services which offer a high percentage and a lower 
percentage of European works. Kantar used the JustWatch database to retrieve this information 
C.  Where possible, the final list of SVoDs per country should contain 2 SVoDs which have an international 
coverage and 2 which are either country-specific or have a more limited geographical coverage. 

Secondly, although the main interest is to analyse the most visible and used SVoDs in each country, it is also 
important  to  understand  if  there  is  any  difference  in  the  level  of  intensity  and  variety  of  the  prominence 
measures used by SVoDs that are visible and have higher percentages of European works and SVoDs that 
are visible and have lower percentages of European works.  

Thirdly,  since  SVoD  platforms  have  become  more  international  in  nature,  it  was  essential  to  be  able  to 
compare, to a certain degree, if those services covering multiple countries tend to promote European works 
and EU27 works/ works from the targeted country to a lesser extent than the more local ones. This is also 
specifically important given that the more international services usually have a higher number of works in their 
catalogues  and  therefore  European  and  EU27  works/  works  from  the  targeted  country  would  become 
significantly less visible without any prominence methods implemented.  

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Thus, the following sources of information and criteria were used to select the 4 SVoDs per country: 

− 

In each of the 15 countries, the top 4 to 5 SVoDs (depending on the availability of data) according to 
the  number  of  subscribers  were  chosen.  For  this,  the  Yearbook  of  the  European  Audiovisual 
Observatory  was  used  whose  main  source  was  AmpereAnalysis.  This  ensured  that  the  SVoDs 
selected were the most visible ones in the targeted country. 

−  Subsequently,  those  SVoDs  were  searched  for  in  the  JustWatch  database  to  check  for  the  total 
number  of  works  overall  and  European  works  specifically  to  ensure  that  the  services  offer  a  high-
enough number of titles and that the number of European works is fairly different among them.  

− 

If a specific SVoD was not part of the JustWatch database, a different SVoD service was chosen. In 
other words, priority was given to the criteria related to the number of titles and European works as 
opposed to being one of the top ones in terms of number of subscribers. However, there were only a 
limited number of cases where the top SVoD service in terms of subscribers could not be found in the 
JustWatch database. Moreover, knowing the total number of works overall and European works could 
be used in the subsequent analysis to understand if there is any difference in the prominence methods 
used  between  services  with  a  high  and  low  number  of  European  works/  works  from  the  targeted 
country.  

The following is the initial list of SVoDs services selected based on the criteria described above, together with 
their corresponding profile (i.e., persona) mentioned in the previous section: 

Table 4: Initial list of SVoD services 
Service 1 

 Country 

Service 2 

Service 3 

Service 4 

Persona40 

AT 

CZ 

DE 

ES 

FR 

HU 

IT 

NL 

PL 

SE 

RO 

Amazon Prime Video  Netflix 

Maxdome 

Sky X 

Netflix 

Amazon Prime Video  Mubi SVoD 

Apple TV Plus 

Amazon Prime Video  Netflix 

TV Now 

WOW (Sky) 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Amazon Prime Video  Rakuten TV 

Mitele Plus 

Amazon Prime Video  Canal+  

Disney Plus 

Amazon Prime Video  HBO GO/Max  Mubi SVoD 

Amazon Prime Video  TimVision 

Mediaset Infinity (Play) 

Amazon Prime Video  VideoLand 

Amazon Prime Video 

IPLA 

NLZiet 

Player 

ViaPlay 

Disney+ 

HBO GO/MAX  Cmore 

HBO GO/MAX  Voyo 

BE (NL/FR)  Netflix 

Amazon Prime Video  Sooner 

Hayu 

SK 

DK 

EE 

Netflix 

Netflix 

Netflix 

Amazon Prime Video  HBO GO/MAX  Voyo 

ViaPlay 

TV2 Play 

HBO GO/MAX 

Amazon Prime Video  Go3 

Mubi SVoD 

1 

2 

1 

2 

1 

2 

1 

2 

1 

2 

1 

2 

1 

2 

1 

4.  The set-up process that led to the collection of high-quality results 

The next step for the mystery shopping exercise was to prepare all the necessary documents that were used 
to brief mystery shoppers, develop the observational grid based on the identified indicators and choose the 
best technical solution for accessing the SVoDs.  

Once the final list of indicators and SVoD services were selected, the Kantar team developed the observational 
grid  which  was  used  by  mystery  shoppers  to  collect  data.  The  full  template  can  be  found  in  Annex  1.  The 
template was designed in a way that contained pre-defined tables and answer options and therefore the data 
could  be  easily  recorded.  However,  importantly,  almost  each  question  also  offered  the  flexibility  to  add 

40 Persona 1: Age 20, gender male, address: random city in the allocated country, Persona 2: Age 55, gender female, address: random 
address in a village in the allocated country. 

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additional comments or notes based on  what mystery shoppers observed  during the  exercise. This way, a 
qualitative assessment can be performed too.  

In addition to this, two other guiding documents were created too: 

−  A mystery shopping guide (or, instructions manual) which explained the process in detail regarding 
how to set up accounts, use the observational grid and defined the necessary terms and the overall 
objective of the exercise. 

−  A mystery shopping power-point presentation with a stronger focus on the technical side, namely the 

steps to be taken to set up the VPN account, email and service accounts. 

On the technical side, there were two main sub-activities performed. Firstly, the Kantar team set up a VPN 
account which could be used by the mystery shoppers. This was essential as the data collection had to be 
conducted  as if the  user was based  in the targeted country.  Secondly, initially, the  approach  was for each 
mystery shopper to create a new email account using one of the following two profiles: 

−  Persona 1: Age 20, gender male, address: random city in the allocated country 
−  Persona 2: Age 55, gender female, address: random address in a village in the allocated country. 

As explained in the previous section too, one of the two profiles was randomly assigned to each of the EU 
Member States analysed.  

In the end, the team only used one persona per service (catalogue). The reason for this is that during the soft-
launch phase, a phase of the fieldwork where the ‘mystery shopping’ process was trialed, the services did not 
show any differences in the titles showed when using different personas. Thus, collecting data using different 
personas would have brought no added value and therefore Kantar decided to divert the focus into analysing 
the data into more depth, both at the country level and across catalogues. 

Finally, a briefing meeting was organised with the mystery shoppers to introduce them to the exercise, explain 
the objectives of the study, define the necessary terms (for example, a ‘European work’), highlight the more 
complex questions and how to use the observational template. The session was recorded and subsequently 
circulated to the entire team for future reference.  The mystery shopping data collection ran from October 25, 
2022, to November 16, 2022. 

5.  Main challenges during the data collection as part of the mystery shopping 

Once the data collection started, there were a few challenges that arouse: 

−  Some of the SVoDs selected could not be accessed via a VPN; the service did not allow the use of 

such a service 

−  Some of the SVoDs required the use of a local bank account (i.e., from the targeted country) to 

access the service 

−  Some of the SVoDs services offered full-packages including ordering a decoder; if the user did not 

want to order it, an account could not be created. 

Given these challenges, a number of the initially selected SVoD services had to be replaced with new ones in 
order to still be able to conduct the analysis for 4 SVoDs per each of the 15 EU Member States. When selecting 
replacement  SVoDs,  priority  was  placed  on  services  that  were  present  in  the  MAVISE  database  and  the 
JustWatch database and on services that had a larger number of European works in the JustWatch database. 
The following is the revised list of the SVoD services per country: 

Country 

Table 5: Revised list of the SVoD services per country 
Platform 2  Replaced 
Replaced 
with 
None 

with 
None 

Netflix 

AT 

Platform 
1 
Amazon 
Prime 
Video 

Platform 3  Replaced 

Platform 4  Replaced 

with 
Sooner 

Sky X 

with 
Filmmit 

Maxdom
e 

CZ 

Netflix 

None 

Amazon 
Prime 
Video 

Voyo 

Mubi 
SVoD 

None 

Apple TV 
Plus 

Filmbox 

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Country 

DE 

Replaced 
with 
None 

Platform 
1 
Amazon 
Prime 
Video 

ES 

Netflix 

None 

FR 

Netflix 

None 

Platform 2  Replaced 

Platform 3  Replaced 

Platform 4  Replaced 

with 
None 

None 

TV Now 

with 
None 

Rakuten 
TV 

None 

None 

Canal+  

None 

WOW 
(Sky) 

Mitele 
Plus 

Disney 
Plus 

Netflix 

Amazon 
Prime 
Video 
Amazon 
Prime 
Video 

HBO 
GO/MAX 

MindigTV  Mubi 
SVoD 

with 
Joyn 
Plus+ & 
Realeyz 

None 

None 

None 

None 

HU 

Netflix 

Disney+  Amazon 

Filmbox 

IT 

Netflix 

None 

NL 

Netflix 

None 

PL 

Netflix 

None 

Prime 
Video 
Amazon 
Prime 
Video 

Amazon 
Prime 
Video 
Amazon 
Prime 
Video 

SE 

RO 

Netflix 

None 

ViaPlay 

Netflix 

None 

Disney+ 

BE 
(NL/FR) 

Netflix 

None 

SK 

Netflix 

None 

DK 

EE 

Netflix 

None 

Netflix 

None 

Amazon 
Prime 
Video 
Amazon 
Prime 
Video 
ViaPlay 

Amazon 
Prime 
Video 

Mubi 
SVoD 
Amazon 
Prime 
Video 
None 

None 

Mubi 
SVoD 
Mubi 
SVoD 

None 

TimVision  Disney+ 

Mediaset 
Infinity 
(Play) 

None 

VideoLan
d 

None 

IPLA 

None 

NLZiet 

None 

None 
(*was 
renamed 
as 
PolsatBox) 
Draken 
Film 
Orange 
TV GO 

Player 

None 

Cmore 

None 

Voyo 

None 

HBO 
GO/MAX 
HBO 
GO/MAX 

Sooner 

None 

Hayu 

None 

HBO 
GO/MAX 

Apple TV 
Plus 

Voyo 

None 

TV2 Play 

C More 

Go3 

None 

HBO 
GO/MAX 
Mubi 
SVoD 

Hayu 

None 

** Services highlighted in red could either not be accessed via a VPN or had one of the other issues mentioned above. Thus, they were 
replaced with new services. 

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3.  Volume 1: Implementing measures of 
Articles 13(1), 13(2), 16 and 17 of AVMSD 

This first volume of the study analyses the implementing measures of Articles 13(1), 13(2), 16 and 17 of the 
revised AVMSD in all EU Member States and EEA countries during the reference period (from 1 January 2020 
to 31 December 2021).  

The first part of the analysis presents the legislative changes related to Articles 13(1), 13(2), 16 and 17 of the 
revised  AVMSD  concerning  television  broadcasting  (linear  services)  and  on-demand  audiovisual  media 
services (non-linear services), which were introduced during the reference period by EU Member States and 
EEA countries.  

The  second  part  of  the  analysis  provides  an  overview  of  financial  contributions  to  the  production  and  the 
acquisition of rights of European works in place in the relevant countries imposing financial contributions for 
linear and on-demand services by the end of the reference period.  

The third part of the analysis examines and details the methodology and the quantitative/qualitative indicators 
established by the competent authorities in EU Member States and non-EU EEA countries in order to monitor 
the application of Articles 13(1), 13(2), 16 and 17.  

In the fourth part of the analysis, we examine the data reported by countries concerning the implementation of 
Articles 13(1), 13(2) 16 and 17 of the AVMSD, and we detail and assess how the Guidelines for calculating 
the share of European works in on-demand catalogues and for exempting certain on-demand services and 
broadcasters with a low turnover or a low audience from cross-border financial contributions to the production 
of European works have been applied in the Member States. 

The last section draws on conclusions on implementing measures of Articles 13(1), 13(2), 16 and 17 of the 
revised  AVMSD  over  the  reference  period,  focusing  on  the  implementation  of  the  increased  obligations  to 
promote European works for on-demand services, following the implementation of the revised AVMSD.  

3.1     Legislative changes affecting linear and non-linear services 

This chapter presents all the legislative changes in national legal frameworks transposing the requirements for 
promoting European works by linear and non-linear service providers set out in Articles 13(1), 13(2) 16 and 17 
of the revised AVMSD, as applied in the period 2020-2021. 

This chapter first provides a general overview of all legislative changes introduced in the EU Member States 
and  in  the  non-EU  EEA  countries  during  the  reference  period,  and  then  presents  the  legislative  changes 
specific to Articles 13(1), 13(2) 16 and 17 of the revised AVMSD.  

3.1.1     General overview of legislative changes 

The table below provides an overview of the legislative changes introduced in the EU Member States and in 
non-EU EEA countries during the reference period, i.e., between 1 January 2020 and 31 December 2021. In 
this table, the symbol “v” should be understood as indicating the presence of legislative changes, while the 
symbol  “x”  should  be  interpreted  as  indicating  their  absence  (including  those  countries  which  introduced 
legislative changes after the reference period).  

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Table 6: Countries that introduced national implementation measures/legislative changes during the 
reference period41 

Art. 13(1) 
obligation for 
on-demand 
audiovisual 
media services 
to secure at 
least a 30 % 
share of 
European 
works 

AT  

BE  

BG 

CZ 

CY 

DE  

DK  

EE  

ES  

EL  

FI  

FR  

HR 

HU  

IE  

IT 

IS 

LI 

LT  

LU 

V 

V 

V 

X 

X 

V 

V 

X 

X 

V 

V 

V 

V 

V 

X 

V 

X 

X 

V 

V 

Art. 13(1) obligation 
to ensure 
prominence 

Art. 13(2) 

Art. 16 

Art. 17 

V 

V 

V 

X 

X 

V 

V 

X 

X 

V 

V 

V 

V 

V 

X 

V 

X 

X 

X 

V 

X 

V 

X 

X 

X 

X 

X 

X 

X 

V 

X 

V 

V 

X 

X 

V 

X 

X 

X 

X 

V 

V 

X 

X 

X 

X 

X 

X 

X 

V 

X 

X 

V 

X 

X 

X 

X 

X 

X 

X 

V 

X 

X 

X 

X 

V 

X 

X 

X 

X 

X 

V 

V 

X 

X 

V 

X 

X 

X 

X 

41 For Articles 16 and 17, the overview table refers to legislative changes which were introduced with regard to these two articles, 
including changes on obligations at national level. For Articles 13(1) and 13(2), the overview table refers to the national implementation 
measures introduced to transpose these new provisions of the revised AVMSD into national law. 

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Art. 13(1) 
obligation for 
on-demand 
audiovisual 
media services 
to secure at 
least a 30 % 
share of 
European 
works 

LV  

MT  

NL  

NO 

PL  

PT  

RO  

SE  

SK 

SI  

V 

V 

V 

X 

X 

V 

X 

X 

X 

X 

Art. 13(1) obligation 
to ensure 
prominence 

Art. 13(2) 

Art. 16 

Art. 17 

V 

V 

V 

X 

X 

V 

X 

X 

X 

X 

X 

X 

X 

X 

V 

V 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Overall, national implementation measures to transpose Article 13 of the revised AVMSD into national 
law were introduced in 17 Member States (AT, BE, BG, DE, DK, EL, HR, HU, FI, FR, IT, LT, LV, LU, MT, 
NL, PT),  while  in ten  EU  Member States (SE,  SK, SI, IE,  EE, ES,  CY,  CZ, RO, PL) and  one  non-EU  EEA 
country (LI), national implementation measures came into force only after the reference period. Furthermore, 
as shown in the table above, legislative changes were introduced in four Member States (AT, BE, EL, HR) as 
regards Article 16 and in five Member States (AT, DE, FR, HR, IT) as regards Article 17. Two non-EU EEA 
countries (IS, NO) did not introduce any national implementation measures to transpose Articles 13(1) and 
13(2) of the revised AVMSD into national law during the reference period. In the case of Articles 16 and 17, 
no new legislative changes were introduced during or after the reference period in non-EU EEA countries. 

3.1.2     Transposition of Article 13(1) – Share and prominence of European works in on-demand 
services  

In 2019, legislation in nine Member States (BG, DE, DK, EL, FI, LU, LV, NL, PT) did not include any specific 
requirements regarding the share of European works or prominence on VOD. During the reference period, 17 
Member States (AT, BE, BG, DE, DK, EL, FI, FR, HR, HU, IT, LT, LU, LV, MT, NL, PT) introduced national 
implementation measures to transpose the Article 13(1) both with regard to the requirement to secure at 
least a 30% share of European works in their catalogues and to ensure prominence of those works. It 
is important to note that 7 Member States (AT, BE42, FR, HR, HU, IT, MT) have had obligations similar to those 
in Article 13 before the revised AVMSD (examples included in Table 7).  Additionally, Lithuania implemented 
changes to transpose the Directive during the reference period regarding the 30% share of European works, 
but no amendments were made with regard to prominence. 

Countries that provide a definition of prominence  

42 Flemish Community and French Community. 

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Currently five Member States (BG, DE, FR, LV, SI) include a definition of prominence in catalogues. It 
should  be  noted  that  three  Member  States  (BE43,  DK,  IT)  and  Norway  have  published  or  plan  to  release 
guidelines elaborating on the notion of prominence.  

Regarding the measures taken to implement the requirement to ensure prominence of European works 
in  on-demand  services,  for  example,  Austrian  legislation  stipulates  that  European  works  have  to  be 
appropriately distinguished from other works by means of a clear identification44, while Finnish law talks about 
ensuring their visibility45. In the Netherlands, there is a requirement for European works to be brought to the 
attention of the public by the channel provider46. The laws of some countries go into greater detail in this regard. 
For  instance,  in  Bulgaria,  the  law  states  that  prominence  involves:  (a)  presenting  European  works  in  an 
attractive  and  accessible  manner,  for  example,  through  a  dedicated  section  for  European  works  that  is 
accessible  from  the  service  homepage,  (b)  the  possibility  to  search  for  European  works  in  the  search  tool 
available as part of that service and (c) the use of European works in that service’s campaigns or a minimum 
percentage  of  European  works  promoted  from  that  service's  catalogue,  for  example,  by  using  banners  or 
similar tools47. In Germany,  the  law specifies that  prominence  may be  ensured by the implementation of a 
special area for European works that is easily recognisable, directly accessible and permanently available from 
the main page of the tele media services48. 

Table 7: Examples of countries already including rules about quota and prominence similar to those 
of  the  revised  AVMSD  before  the  transposition  deadline,  in  which  additional  changes  were  made 
during the reference period   

To give an example, Belgium (Flemish Community and French Community) and France have had similar obligations to those laid down 
in the revised AVMSD already before the reference period., Additional legislative changes were made in the reference period.    

In the Flemish Community of Belgium, there was already an obligation before the reference period for VoD providers to reserve 30% 
of the catalogue for European works and to ensure their prominence9.    

In  the  French  Community,  before  the  revised  AVMSD’s  transposition  deadline,  the  law  provided  for  an  obligation  for  VoD  service 
providers to ensure the prominence of European works10. The New Decree of 4 February 2021 on audiovisual media services and 
video sharing services specifies that the publishers of services must offer a minimum of 30% of European works in their non-linear 
television services, of which one-third must be audiovisual works of French-speaking Belgian initiative. During an initial period of five 
years from the entry into force of the decree, the quota of European works must increase gradually each year until it reaches 40%, and 
beyond this five-year period, the Government may "set higher proportions". The rules regarding prominence were also updated and 
currently on-demand audiovisual media service providers are required to communicate to the regulator a list of information, such as a 
description of the VoD service’s strategy in terms of the promotion of European works, promotion tools and campaigns, etc11. 

Before the revised AVMSD’s transposition deadline, France already had a law including the obligation for on-demand service providers 
to have a minimum of 60% of European works in their catalogues, as well as prominence requirement49. In the reference period, some 
further changes were made with regard to Article 13(1)12. Fewer services are subject to the new obligations and there is a requirement 
whereby  the  catalogue  has  to include  at  least  50%  of  European  works50.  The  provisions  containing  the  requirements  for  ensuring 
prominence were also extended13.  

3.1.3     Transposition  of  Article  13(2)  -  Financial  contributions  made  by  VoDservices  in  European 
works 

In  the  case  of  Article  13(2),  seven  Member  States  (BE,  EL,  FR,  HR,  IT,  PL,  PT)  introduced  national 
implementation measures during the reference period.14 Member States (BG, CY, DK,  EE, FI, HU, IE, 
LT, LU, LV, MT, NL, RO, SE) and three EEA countries (IS, LI, NO) did not introduce financial obligations for 
the promotion of European works. Conversely, 13 Member States (AT, BE, CZ, DE, ES, EL, FR, HR, IT, PL, 

43 French Community. 

44 Section 40(1) of the Audiovisual Media Services Act. 

45 Law amending the Act on Electronic Communications Services 917/2014. 

46 Article 2.115 of Media Act 2008. 

47 Article 19 of the Radio and Television Act. 

48 Article 77 of the Interstate Media Treaty. 

49 Articles 11-13 of Decree No. 2010-1379 of 12 November 2010. 

50 Articles 27-29 of Decree No. 2021-793 of 22 June 2021. 

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PT, SI, SK) had direct and/or indirect financial obligations for VoD services. Out of these 13 Member States, 
six  Member  States  (AT,  CZ,  DE,  ES,  SI,  SK)  introduced  no  changes  during  the  reference  period,  but  the 
requirement with regard to financial contribution already existed prior to the reference period. At the same time, 
7 Member States (BE51, EL, FR, HR, IT, PL, PT) have made changes related to financial contributions of VoD 
services.  Furthermore,  7  Member  States  (BE,  DE,  EL,  FR,  HR,  IT,  PL)  reported  having  in  force  financial 
contribution obligations to cross-border services during the reference period.  

In  the  following  paragraphs,  the  legislative  changes  by  the  aforementioned  seven  Member  States  are 
elaborated. All the changes in question are presented in the overall table below in Table 12. 

In the French-speaking community in Belgium, since February 2021, local and foreign VoD services which 
target  the  French-speaking  audience  have  been  required  to  contribute  to  the  production  of  the  audiovisual 
works52. This contribution takes the form of either the co-production or pre-purchase of audiovisual works, or 
a payment to the Centre du cinéma et de l'audiovisuel (National Centre for Cinema and the Moving Image).  

In Croatia, before the recent legislative changes introduced in 2021, the law stipulated that VoD services were 
subject to a levy of 2% of the revenues generated by the service53. The revised Electronic Media Act states 
that providers of on-demand audiovisual media services are required to invest 2% of the total annual gross 
income  in the production  of Croatian audiovisual  works by independent  producers  or to purchase Croatian 
audiovisual  works  produced  by  independent  producers.  It  further  makes  a  reference  to  non-domestic  on-
demand service providers and stipulated that they are also obliged to: (a) pay a financial contribution for the 
implementation  of  the  National  Program  for  the  Promotion  of  Audiovisual  Creativity  for  the  production  of 
European works in accordance with the law regulating audiovisual activity, and (b) invest 2% of the total annual 
gross income in the production of Croatian audiovisual works by independent producers or purchase Croatian 
audiovisual works produced by independent producers54.  

In France, prior to the reference period, VoD services were subject to both a direct investment obligation and 
a levy to be paid to the film fund. The tax rate, previously set at 2%, was increased to 5.15% for 202055. The 
law was further updated during the reference period. Investment obligations are now defined in Decree 2021-
793 of 22 June 2021 for on-demand audiovisual media services, which moreover  increased the rate of the 
direct investment obligation for SVoD services to 20-25%. These investment obligations apply to both domestic 
and  non-domestic  on-demand  audiovisual  media  services  (before  the  new  Decree,  investment  obligations 
applied only to domestic VoDs).   

In Greece, even before the period under review, the applicable law56 established requirements on financial 
contributions to the production of audiovisual works. The law specified that Pay-TV companies had to allocate 
each year 1.5% of their annual advertising revenues to the production of cinematographic works. Furthermore, 
the law required companies providing telecommunication services and new technologies to allocate each year 
1.5%  of  their  annual  turnover  resulting  from  the  provision  of  audiovisual  media  services  via  the  internet  or 
mobile telephony (IPTV, VoD) to the production of cinematographic works. These legal provisions are still in 
force. Additionally, the new law57 which was introduced to comply with the revised AVMSD now specifically 
addresses  on-demand  media  service  providers  established  in  another  Member  State,  as  long  as  they 
specifically  target  Greek  audiences.  Such  service  providers  are  obliged  to  contribute  financially  every  year 
1.5%  of  their  turnover  associated  with  their  operations  in  Greece,  either  a)  for  the  production  of  Greek 
audiovisual works, or b) for the acquisition of rights in Greek audiovisual works that have not yet been released, 
or c) by paying the relevant amount into a dedicated account of the National Centre of Audiovisual Media and 
Communication S.A., to support Greek productions. 

51 French Community. 

52 Decree of 4 February 2021 on audiovisual media services and video sharing services. 

53 Article 25 of the Audiovisual Activities Act. 

54 Articles 27, 28 of Electronic Media Act. 

55 Law 2019-1479 of 28 December 2019. 

56 Law 3905/2010. 

57 Law 4779/2021. 

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In Italy, while before the reference period the applicable law58 imposed a requirement to invest 12.5% of annual 
net revenues, the new law which came into force on 25 December 2021 and becomes applicable after the 
current reference period stipulates that on-linear media service providers subject to the Italian jurisdiction must 
invest as follows in European works: 17% up to 31 December 2022, 18% from 1 January 2023 and 20% from 
January 202459.  

In Poland, the Act of 14 May 2020 introduced an obligation for on-demand audiovisual media service providers 
to contribute to the Polish Film Institute an amount equal to 1.5% of the revenues generated by the fees for 
accessing  the  on-demand  audiovisual  media  services  made  available  to  the  public  or  of  the  revenues 
generated  by  the  broadcasting  of  commercial  communications,  if  those  revenues  were  higher  in  the  given 
reference  period.  Equally,  the  same  obligation  was  imposed  on  on-demand  audiovisual  media  service 
providers having their registered office in another Member State of the European Union. The amount of the 
contribution  due  is  determined  on  the  basis  of  the  revenues  generated  in  the  territory  of  the  Republic  of 
Poland60. Before 2020, there were no specific legal measures in place obliging non-linear service providers to 
contribute financially to the production of European works.  

In Portugal, as a result of legislative changes introduced in 2020, the operators of television services or on-
demand audiovisual services, distributors of cinematographic works and videogame editors must now allocate 
part of their investment expenses to the development, production and promotion of European and Portuguese-
language  works,  as  well  as  works  of  independent  production 61.  The  amounts  to  be  invested  by  private 
operators are defined according to their relevant income. Also, the law in  Portugal establishes the need for 
payment of an "exhibition fee" of €2 per subscriber/year62. The new rules only entered into force in 2022. 

3.1.4     Level of requirements of Article 13 adopted by EU Member States and non-EU EEA countries 

This sub-section presents a general overview of the quotas and sub-quotas required at national level for the 
promotion of European Works in non-linear services. 

The  table  below  highlights  specific  rules  on  quotas  ensuring  that  European  works  represent  a  majority 
proportion, and also indicates specific quotas and sub-quotas in Member States and non-EU EEA countries in 
relation to non-linear services. 

Table 8: Level of requirements for Article 13 in Member States and non-EU EEA countries 

Country 

Quotas for majority proportion of European Works and other sub-quotas for non-linear services 

AT 

BE 

“ensure at least 30% of the titles in the respective catalogue are European works” 

-  French  Community:  must  offer  a  minimum  of  30%  of  European  works  in  their  non-
linear audiovisual services, of which one-third must be audiovisual works of French-
speaking Belgian initiative. In the first five years after the entry into force of the new 
Decree,  the  30%  quota  of  European  works  increases  gradually  each  year  to  40%. 
Afterwards,  the  government  can  set  higher  proportions,  on  the  basis  of  a  prior 
assessment by CAC. 

-  Flemish  Community:  ensure  at  least  30%  of  European  works  in  their  programme 
catalogue,  of  which  a  “considerable  part”  must  be  ensured  for  Dutch-speaking 
European works 

-  German-speaking  Community:  ensure  at  least  30%  of  European  works  in  their 

catalogues 

BG 

“the share of European works must be not less than 30% of the total number of VoD available 
on the platform” 

58 Consolidated Law on Audiovisual and Radio Media Services. 

59 Consolidated Law on Audiovisual Media Services. 

60 Article 19 of Cinematography Act. 

61 The Law 55/2012 amended by the Law 74/2020. 

62 Ibid.  

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Country 

Quotas for majority proportion of European Works and other sub-quotas for non-linear services 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

“shall secure at least 30% share of European works in their list” (since 2022) 

“reserve for European works at least 30% of the total number of programmes offered in the 
programme catalogue” (since 2022) 

“ensure that the proportion of European productions in their catalogues makes up at least 30%” 

“ensure that European works comprise at least 30% of the programme catalogue” 

“ensure that at least 30% of the programmes in its programme catalogue are European works” 
(since 2022) 

“ensure that their catalogues include European works in a proportion of at least 30%” 

“reserve at least 30% of the catalogue for European works” (since 2022): 

-  At least 50% of this quota shall be reserved for works in the official language of Spain 
or in one of the official languages of the Spanish Autonomous Communities. Of this 
sub-quota,  the  provider  of  the  on-demand  television  audiovisual  communication 
service at State level shall reserve a minimum of 40% for audiovisual works in any of 
the official languages of the Autonomous Communities, taking into consideration their 
population weight and reserving at least 10% for each of them. 

Furthermore,  a  minimum  of  70%  of  the  funding  obligation  must  be  allocated  to  audiovisual 
works  produced  by  independent  producers,  on  their  own  initiative  or  by  commission,  in  the 
official  language  of  Spain  or  in  one  of  the  official  languages  of  the  Spanish  Autonomous 
Communities. Of this sub-quota, the provider of the television, linear or on-demand audiovisual 
communication service shall reserve in any case: 

- A minimum of 15% to audiovisual works in the official languages of the Spanish Autonomous 
Communities, taking into account their population weight and reserving at least 10% for each 
of them. 

- A minimum of 30% to audiovisual works directed or created exclusively by women. 

Above that, a minimum of 40% of the funding obligation must be allocated to cinematographic 
films produced by independent producers, on their own initiative or by commission, of any film 
genre in the official language of Spain or in any of the official languages of the State or in one 
of the official languages of the Spanish Autonomous Communities. 

“reserve at least 30% of its catalogue for European works” 

“shall reserve in the total number of full-length cinematographic works on the one hand and 
audiovisual works on the other hand made available to the public a share at least equal to: 

- 60% for European works; 

- 40% must be ensured for works of original French expression. 

The agreements with Arcom can set lower proportions than 60% (but not less than 50%) if the 
audiovisual  media  service  provider  makes  a  commitment  to  invest  in  the  production  of 
unpublished  audiovisual  works  of  original  French  expression  produced  by  independent 
production companies”. 

“must provide at least 30% of the share of European works in their catalogues” 

- 

- 

“30% of the total sum of the length of the programmes (…) of on-demand audiovisual 
media services shall be composed of European works” 

“10% shall be composed of Hungarian works” 

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Country 

Quotas for majority proportion of European Works and other sub-quotas for non-linear services 

IE 

IS 

IT 

LI 

LT 

LU 

LV 

MT 

NL 

NO 

PL 

PT 

RO 

SE 

SI 

“shall not provide an audiovisual on-demand media service with a catalogue in which the share 
of European works is less than 30%” (since 2023) 

“ensure at least 30% of content on offer is European works” (draft law) 

- 

“reserve at least 30% of their catalogues to European works, of which at least 50% 
shall be reserved to works of original Italian expression produced in the last five years 
by independent producers; an additional sub-quota here is that a fifth of the 30% quota 
shall  be  reserved  to  cinematographic  works  of  original  Italian  expression  by 
independent producers” 

- 

“reserve at least 30% of their catalogues to European works produced in the last five 
years” 

“ensure, that their catalogues contain a minimum proportion of European works of 30%” (draft 
law) 

“ensure that at least 30% of the programme catalogue contains European works” 

“ensure that at least 30% of the programme catalogue contains European works” 

ensure “at least 30 % of European audiovisual works in its catalogue” 

“ensure that their catalogues contain at least a minimum share of 30% of European works” 

“on-demand audiovisual media offer consists, per supply channel, of at least 30% European 
works” 

“at least 30% European works in their catalogues” (draft law) 

“shall devote at least 30% of the catalogue content to European broadcasts, including those 
which were originally produced in Polish” (since 2022) 

“ensure  at  least  30%  of  European  works  of  their  programmes,  and  at  least  50%  of  this 
proportion must be dedicated to creative works of independent European production, originally 
in Portuguese and produced less than five years ago” 

“at least a 30% share of European works in their catalogues” (since 2022) 

“ensure that at least 30% of the catalogue consists of programmes of European origin” (since 
2022) 

- 

- 

“the  share  of  European  audiovisual  works  must  represent  at  least  30%  of  the  total 
number of works in the catalogue of the on-demand audiovisual media service provider 
(since 2022) 

the  share  of  Slovenian  audiovisual  works  must  represent  at  least  5%  of  the  total 
number  of  works  in  the  catalogue  of  the  on-demand  audiovisual  media  service 
provider” (since 2022) 

SK 

“reserve at least 30% of the total number of programmes” (since 2022) 

-  Share  

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As mentioned in section 3.1.2   17 EU Member States (AT, BE, BG, DE, DK, EL, FI, FR, HR, HU, IT, LU, LT, 
LV, MT, NL, PT) introduced national implementation measures to transpose Article 13(1) both with regard to 
the  requirement  to  secure  at  least  a  30%  share  of  European  works  in  their  catalogues  and  to  ensure 
prominence of those works during the reporting period. The remaining ten Member States (CY, CZ, EE, ES, 
IE, PL, RO, SE, SI, SK) and the non-EU EEA countries (IS, LI, NO) transposed the relevant provisions only 
after the reporting period. 

Most Member States have established concrete percentage requirements for the share of European works 
in  catalogues.  16  Member  States  require  audiovisual  media  service  providers  to  have  30%  of  European 
works in their catalogues (AT, BE63, BG, DE, DK, EL, FI, HR, HU, IT, LT, LU, LV, MT, NL, PT). Two Member 
States (BE64, FR) have established quotas higher than 30% to be ensured for European works in catalogues. 

Seven Member States (BE65, ES, FR, HU, IT, PT, SI) have introduced  sub-quotas for works of original 
expression.  Moreover,  four  Member  States  (ES,  FR,  IT,  PT)  have  sub-quotas  regarding  works  of 
independent producers, and two Member States (IT, PT) have established sub-quotas for recent works. 

3.1.5     Legislative changes with regard to Article 16 – promotion of European works in linear 
services 

As Article 16 of the AVMSD had already been transposed in all the Member States before the reference period, 
the following paragraphs will highlight new legislative changes in the laws of Member States related to this 
article. During the reference period, four Member States (AT, BE, EL, HR) introduced such legislative changes. 
Based  on  our  findings,  the  German-speaking  Community  of  Belgium  enacted  the  new  German-speaking 
Community Decree on media services and cinematographic performances66 in the reference period (in 2021, 
replacing  the  previous  Decree 67),  by  which  the  legislator  introduced  legislative  changes  transposing  the 
provision  laid  down  in  Article  16  of  the  AVMSD.  Beyond  that,  two  Member  States  (RO,  SK)  made  minor 
changes concerning Article 16 in their legislation after the reference period. 

In the non-EU EEA countries (IS, LI, NO), Article 16 of the AVMSD had already been transposed before the 
reference period. No legislative changes related to Article 16 were made during the reference period. 

Legislative changes 

In Austria, the wording was changed in 2020 from “where practicable” and “by appropriate means” 68 to “as far 
as possible” and “by applying reasonable means”69 respectively. Moreover in 2020, the law transposing Article 
16  was  amended,  since  the  provision  requiring  that  the  majority  proportion  of  European  works  “is  to  be 
achieved progressively in the fields of information, education, culture and entertainment on the basis of suitable 
criteria”70 has been removed from the legislation. 

In Belgium, in the French Community, the majority proportion of European works includes original works by 
authors from the French Community, called “audiovisual works of French-speaking Belgian origin”. The new 
French Community Decree of 2021 combined the substance of certain articles of the old decree 71  into a single 

63 Flemish Community and German-speaking Community. 

64 French Community. 

65 French Community and Flemish Community. 

66 Decree of the Ministry of the German-speaking Community of 1 March 2021 on media services and cinematographic performances. 

67 Decree of the Ministry of the German-speaking Community of 27 June 2005 on media services and cinematographic performances. 

68 Article 50 of the Federal Act on Audio-visual Media Services (AMD-G) (consolidated version of 30 July 2015)  (Bundesgesetz über 
audiovisuelle Mediendienste/Audiovisuelle Mediendienste-Gesetz AMD-G) and Article 11 of the Federal Act on the Austrian 
Broadcasting Corporation (ORF-G) (consolidated version of 31 July 2017)  (Bundesgesetz über den Österreichischen Rundfunk /ORF-
Gesetz ORF-G). 

69 Article 50 of the Federal Act on Audio-visual Media Services (AMD-G) (consolidated version of 30 July 2015)  (Bundesgesetz über 
audiovisuelle Mediendienste/Audiovisuelle Mediendienste-Gesetz AMD-G). 

70 Article 50 of the Federal Act on Audio-visual Media Services (AMD-G) (consolidated version of 30 July 2015)  (Bundesgesetz über 
audiovisuelle Mediendienste/Audiovisuelle Mediendienste-Gesetz AMD-G) and Article 11 of the Federal Act on the Austrian 
Broadcasting Corporation (ORF-G) (consolidated version of 31 July 2017) (Bundesgesetz über den Österreichischen Rundfunk /ORF-
Gesetz ORF-G). 

71 Article 43 and Article 44 of Decree of the Government of the French Community coordinating the decree on audiovisual media 
services of 26 March 2009. 

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article 72  and  thus  provided  for  various  quotas,  applicable  only  to  linear  TV.  The  rule  on  the  majority  of 
broadcasting time for European works (and the exceptions provided) did not change in 2020-2021 in relation 
to 2019. Further rules on quotas will be described under a separate sub-chapter. It should be noted that a 
higher quota (55%) already existed for the public broadcaster RTBF before 2019 regarding the broadcasting 
proportion of European works, which was raised to 60% in 2021, under the fifth management contract of RTBF. 
No changes were identified for the Flemish Community. 

In Croatia, a change in the obligation for private broadcasters was made based on Article 16 of the AVMSD. 
In 2019, Croatian legislation73 laid down that private broadcasters should make their best efforts to reserve a 
majority proportion of their annual transmission time for European works, with the minimum initial proportion 
of 20% (with the aim of progressively increasing this proportion every year). An amendment in 2021 74 changed 
this rule to an obligatory quota of more than 50%, which means that such an amount of transmission time for 
European works must be ensured by private broadcasters (and at least 50% of this transmission time must be 
reserved for Croatian audiovisual works). For the public broadcaster (HRT), the obligation to ensure 51% of 
transmission time to European works75 did not change during the reference period. 

In  Greece,  in  2019,  the  law76 required  broadcasters  to  reserve  at  least  51%  of  their  transmission  time  for 
European works. In 2021, the wording was changed, and now the required transmission time for European 
works  by  broadcasters  “exceeds  50%”77 (in  both  cases,  the  proportion  was  calculated  on  an  annual  basis, 
based on the total transmission time). 

3.1.6     Legislative changes with regard to Article 17 – share of European Works in linear services 

As Article 17 of the AVMSD had already been transposed in all the Member States before the reference period, 
the  following  paragraphs  will  highlight  new  legislative  changes  in  Member  State  legislations  related  to  this 
article.  During  the  reference  period,  five  Member  States  (AT,  DE,  FR,  HR,  IT)  introduced  such  legislative 
changes. Additionally, five Member States (ES, HR, NL, PL, SE) made amendments to their respective laws 
related to Article 17 of the AVMSD after the reference period. 

Legislative changes 

In the non-EU EEA countries (IS, LI, NO), Article 17 of the AVMSD had already been transposed before the 
reference period. No legislative changes related to Article 17 of the AVMSD were made during the reference 
period. 

Five EU Member States (AT, DE, FR, HR, IT) introduced legislative changes related to Article 17 of the 
AVMSD in the reference period: 

In Austria, new legislative changes were introduced in the reference period. In 2019 legislation provided for 
an exception for private broadcasters, laying down that private broadcasters needed to achieve this proportion 
“where practicable and by appropriate means”. In 2021, the Austrian law78 was amended as follows: 

72 Article 4.2.1 - 1. of Decree of 4 February 2021 on audiovisual media services and video sharing services (Décret du 4 février 2021 
relatif aux services de médias audiovisuels et aux services de partage de vidéos). 

73 Article 42 of Electronic Media Act of 2009 (Zakon o elektroničkim medijima). 

74 Article 48 of the Electronic Media Act (Zakon o elektroničkim medijima). 

75 Article 42 of Electronic Media Act (Zakon o elektroničkim medijima) and Article 10 of Croatian Radio-television Act (Zakon o Hrvatskoj 
radioteleviziji). 

76 Article 17 of Presidential Decree 109/2010 (FEK A 190) harmonising Greek broadcasting legislation with the provisions of Directive 
2010/13/EE (OJ L 95 of 15.4.2010) of the European Parliament and of the Council, which codified the provisions of Directive 
89/552/EEC (OJ L 298, 17.10.1989) of the Council. 

77 Article 20 of Law 4779/2021 (FEK A 27), transposing into national legislation Directive (EU) 2010/13 of the European Parliament and 
of the Council of 10 March 2010 on the coordination of certain legislative, regulatory and administrative provisions of the Member States 
regarding the provision of audiovisual media services, as amended by Directive (EU) 2018/1808 of the European Parliament and of the 
Council of 14 November 2018 and other provisions of the competence of the General Secretariat for Communication and Information. 

78 Article 50 of the Federal Act on Audio-visual Media Services (AMD-G) (consolidated version of 30 July 2015)  (Bundesgesetz über 
audiovisuelle Mediendienste/Audiovisuelle Mediendienste-Gesetz AMD-G) and Article 11 of the Federal Act on the Austrian 
Broadcasting Corporation (ORF-G) (consolidated version of 31 July 2017)  (Bundesgesetz über den Österreichischen Rundfunk /ORF-
Gesetz ORF-G). 

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−  an obligation related to recent works was introduced in 2021 through an amendment to the Federal 
Act on Audio-visual Media Services79, which stipulates that “a reasonable share shall be reserved to 
more recent works”; 

− 

the legislator added shows to the list of exclusions and removed teleshopping services from the list. 

The revised regulation provides, for all television broadcasters, that the minimum of 10% of transmission time 
reserved for European works of independent producer should only apply “as far it is possible and by applying 
reasonable means” and that this proportion “should be reached gradually by means of suitable criteria in the 
areas of information, education, culture and entertainment”. This means that the wording of “where practicable 
and by appropriate means” has been changed to “as far as possible and by reasonable means”. Moreover, 
new more detailed provisions were added from Article 17 of the AVMSD on how to achieve this proportion. 
Furthermore, since 2021, this provision covers not only private broadcasters but all broadcasters. 

In Croatia, in 2021, a new provision was introduced in relation to the situation in 2019. According to the new 
provision, broadcasters that start to broadcast after 22 October 2021 (the day when the amendment to the 
Electronic Media Act came into force) shall reach the proportion of transmission time reserved for European 
works gradually by means of suitable criteria in the areas of information, education, culture and entertainment. 
The minimum quota for the proportion of transmission time is set at 20% and can gradually be increased from 
that level. 

In France, in 2021, new legislation80 introduced obligations requiring contributions to independent productions. 
The law provides that a certain percentage of the contribution to productions must take the form of investments 
in independent production, and the share of investment depends on the service. The new rules distinguish 
between free-to-air television services and, among paid services, publishers of cinema services, publishers of 
pay-per-view services, and publishers of services other than cinema or pay-per-view services. In addition, it 
refers to individual “agreements” (Agreements with Arcom, the Regulatory Authority for Audiovisual and Digital 
Communication in France) in terms of establishing, specifying and sometimes modifying some obligations. It 
should be noted that the French legislation regarding Article 17 of the AVMSD does not follow the wording of 
the Directive. 

In Germany, the following changes were introduced:  

−  According  to  the  Twenty-Second  Interstate  Treaty  amending  the  Interstate  Treaty  on  Broadcasting 
(RStV)81 -  which  entered  into  force  in  May  2019  -  general  television  channels  (i.e.,  a  broadcasting 
service of varied content with information, education, advice, and entertainment forming a major part 
of the overall programming) should comprise a significant proportion of own productions as well as 
commissioned  and  joint  productions  originating  in  the  German-language  regions  and  Europe  as  a 
whole. The same requirement relates to thematic channels as far as this is feasible regarding their 
focus in terms of content. 

−  Furthermore, it should be mentioned that the German legislation does not follow the wording of the 
AVMSD. This means that the production quota of Article 17 of the AVMSD, which refers specifically to 
"independent" productions and according to which national broadcasters should, as far as practicable, 
devote at least 10% of their broadcasting time or alternatively 10% of their budget to European works 
produced by independent producers, is not expressly reflected in German law specifically either in the 
form of the broadcasting time-related production quota or in the form of the investment-related quota. 
Nevertheless, the majority of German broadcasters already comply with the “independent production 
quota” requirement.  

79 Article 51 of the Federal Act on Audio-visual Media Services (AMD-G) (consolidated version of 30 July 2015) (Bundesgesetz über 
audiovisuelle Mediendienste / Audiovisuelle Mediendienste-Gesetz AMD-G). 

80 Decree No. 2021-1924 of 30 December 2021 on the cinematographic and audiovisual contribution of publishers of television services 
distributed by networks not using frequencies assigned by the Audiovisual and Digital Communication Regulatory Authority; and Decree 
No. 2021-1926 of 30 December 2021 on the contribution to the production of cinematographic and audiovisual works of television 
services broadcast over the ground. 

81 Interstate Treaty on Broadcasting and Telemedia (Interstate Broadcasting Treaty - RStV) of 31 August 1991 as amended by the 
Twenty-Second Interstate Treaty amending the Interstate Treaty on Broadcasting in force as of 1 May 2019 (Staatsvertrag für Rundfunk 
und Telemedien [Rundfunkstaatsvertrag – RStV]). 

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In  Italy,  a  change  in  the  legislation  in  2021  in  relation  to  2019  is  noteworthy:  the  Consolidated  Law  on 
Audiovisual  and  Radio  Media  Services  (CLARMS) 82 changed  the  proportions  as  regards  the  budget  to  be 
reserved for independent production. For commercial linear services, the proportion was raised from  10% to 
12.5%, while for public media service providers, the share was raised from 15% to 17%. 

EU  Member  States  with  rules  on  the  obligation  of  reserving  a  certain  percent  of  the  programming 
budget for independent European works created by independent producers 

The revised AVMSD lays down that Member States shall ensure that broadcasters reserve at least 10% of 
their transmission time or alternately, at least 10% of their programming budget for European works created 
by  independent  producers.  Consequently,  Member  States  have  the  alternative  to  fulfil  their  obligation 
byreserving at least 10% of their programming budget for European works created by producers who are 
independent of broadcasters. This provision appears (in parallel with the provision on reserving at least 10% 
of their transmission time for European works (see under 2.2.5.4) created by independent producers) in 13 EU 
Member States: AT, BE83, CY, CZ, DK, FI, IE, IT, MT, NL, RO, SK and SE. No amendments to the provision 
on reserving 10% of the budget in these Member States were made in either 2020 or 2021. At the same time, 
in  14  Member  States, there is  no  obligation for broadcasters to reserve at least  10% of their  programming 
budget for European works of independent producers: BE84, BG, DE, EE, EL, ES, HR, HU, LU, LT, LV, PL, 
PT, SI. No provision on the programming budget in the aforementioned Member States existed in 2019, and 
no amendments related to this obligation were made in 2020 or 2021. 

In three Member States, specific rules apply to the programming budget: 

−  Croatia: in 2019, the public broadcaster (HRT) was obliged to reserve 15% of its programming budget 
for European works created by producers who are independent from broadcasters (and at least 7.5% 
for Croatian works). The obligation for private broadcasters is that such service providers must reserve 
at least 10% of their transmission time for European works created by producers who are independent 
from broadcasters, and at least half of these works must be made within five years. The provisions in 
force in 2019 did not change in the reference period. In addition, since 2021, private broadcasters are 
required  to  ensure  at  least  5%  of  their  annual  gross  income  from  the  previous  year  is  allocated  to 
Croatian independent works. 

−  Finland: the legislator has set the proportion of programming budget reserved for European works at 

19%. There was no change in the reference period. 

−  Slovakia:  the  legislator  has  set  the  proportion  of  the  programming  budget  reserved  for  European 
works at 15% for public broadcasters and 10% for private broadcasters. There was no change in the 
reference period. 

Concerning  non-EU  EEA  countries,  Iceland  and  Liechtenstein  provide  the  opportunity  for  linear  service 
providers to reserve at least 10% of their programming budget for European works created by independent 
producers, in parallel with the option to reserve at least 10% of transmission time for European works created 
by independent producers. At the same time, in Norway, there is no provision for reserving at least 10% of the 
programming budget, only the obligation to reserve at least 10% of transmission time applies. No legislative 
changes related to these obligations were made during the reference period. 

EU Member States with rules on the obligation to reserving a certain percentage of the transmission 
time to European works created by independent producers 

Before  2019,  four  Member  States  (BG,  FI,  HR,  SK)  already  had  special  rules  related  to  the  obligation  of 
reserving 10% of transmission time to European works created by independent producers, as follows: 

−  Bulgaria: the obligation of broadcasters to reserve transmission times for European works was set at 
12% instead of 10% in the reference period (this provision was introduced before 2019 and was not 
changed between 2019 and 2021). 

−  Croatia:  the  legislator  distinguished  between  the  obligations  of  private  broadcasters  (transmission 
time reserved for European works set at 10%) and public broadcasters (transmission time reserved 

82 Legislative Decree no. 177 of 31 July 2005 on Audiovisual and Radio Media Services (CLARMS). 

83 German-speaking Community. 

84 French Community and Flemish Community. 

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for European works set at  15%). This provision  was introduced before  2019 and was not changed 
between 2019 and 2021. 

−  Finland: the obligation of broadcasters to reserve transmission times for European works was set at 
19% instead of 10% in the reference period (this provision was introduced before 2019 and was not 
changed between 2019 and 2021). 

−  Slovakia: the legislator distinguished between the obligations of private broadcasters (transmission 
time reserved for European works set at 10%) and public broadcasters (transmission time reserved 
for European works set at  15%). This provision  was introduced before  2019 and was not changed 
between 2019 and 2021. 

2.2.6 Technical/minor changes of Article 16 and Article 17 

It should be noted that  eight EU  Member  States (AT, BE, CY,  DE, DK,  EL, HR, MT) introduced  legislative 
changes in the reference period, but these changes were technical ones (for example numbering changes due 
to  amendments  not  concerning  Articles  16  and  17).  Moreover,  in  the  reference  period  (2019-2021),  the 
provision “where practicable and by appropriate means” from Article 17 of the AVMSD does not appear in the 
legislation of Member States and non-EU EEA countries, except in Ireland, and partially in Lithuania and Latvia. 
In  Latvia  and  in  Lithuania,  the  terms  “where  practicable”  and  “when  possible”  appear  respectively  in  their 
legislation. 

3.1.7     Level of requirements of Articles 16 and 17 adopted by EU Member States and non-EU EEA 
countries 

In accordance with Article 16, all Member States require TV broadcasters to reserve a majority proportion 
of their transmission time for European works. Twenty-one Member States (AT,BE85, BG, CY, CZ, DE, 
DK, EL, FI, HU86, IE, LU, LT, MT, NL, PL, PT, RO, SE, SI, SK) and the non-EU EEA countries (IS, LI, NO) 
have transposed the exact EU quotas (majority of European works), while four Member States have introduced 
slightly higher quotas with a minimum of 51% (EE, ES, HR, LV), and two Member States have opted for a 
significantly higher quota of at least 60% for European works (FR, IT). Furthermore, two Member States require 
public broadcasters to comply with higher quotas (BE87, HU).  

Furthermore,  nine  Member  States  have  specific  quotas  on  works  produced  in  their  official  languages 
(“works of original expression”) (EL, ES, FR, HR, HU, IT, LV, PL, PT). 

The  table  below  highlights  specific  rules  on  quotas  ensuring  that  European  works  represent  the  majority 
proportion, and also indicates specific quotas and sub-quotas in Member States and non-EU EEA countries in 
relation to linear services. 

Table 9: Level of requirements for Article 16 in Member States and non-EU EEA countries 

Country 

Quotas for majority proportion of European Works and other sub-quotas for linear services 

AT 

BE 

(not specified) ‘majority proportion of transmission time’ 

French Community: 

-  For  commercial  broadcasters  (not  specified)  “majority  proportion  of  broadcasting 

time” 

-  For public broadcaster (RTBF): 60% (55% before 2021) 

Flemish Community: 

-  For  commercial  broadcasters  (not  specified)  “majority  proportion  of  broadcasting 

time” 

-  For public broadcaster (VRT) a sub-quota of 65% exists during prime time  

85  Applies to all communities of Belgium. 

86 For commercial audiovisual media service providers. 

87 French Community and Flemish Community. 

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Country 

Quotas for majority proportion of European Works and other sub-quotas for linear services 

German-speaking Community: (not specified) “majority proportion of broadcasting time” 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

At least 50% 

(not specified) “reserve the majority percentage of their transmission time” 

(not specified) “more than half of the total broadcast time” 

(not specified) ‘majority proportion of transmission time’ 

(not specified) “more than half of transmission time” 

At least 51% 

“More than 50%” 

More than 25% of this proportion must be in Greek as the original language 

ES 

At least 51%  

50% of this proportion must be reserved for European works in any of the Spanish languages 

FI 

FR 

(not specified) “major part of broadcasting time” 

“proportion of broadcasting time at least equal to 60% of European (cinematographic) and 
audiovisual works”  

At least 40% of this proportion must be (cinematographic) and audiovisual works of original 
French  expression  (linear  audiovisual  service  providers  distributed  by  networks  not  using 
frequencies assigned by Arcom may set lower proportions for the broadcasting of audiovisual 
works, but the proportion provided for European works cannot be lower than 50%) 

HR 

At least 51%  

40% of this proportion must be dedicated to ‘Croatian audiovisual works’ (works of original 
Croatian expression)88 

HU 

(not  specified)  “over  half  of  its  annual  transmission  time”  and  “over  one-third  of  its 
transmission time to broadcasting Hungarian works” 

-  For the public broadcaster 60% of its annual transmission time must be reserved for 
European  works  (50%  of  this  proportion  must  be  reserved  for  ‘Hungarian  works’ 
(works of original Hungarian expression))89 

IE 

IS 

IT 

(not specified) “majority proportion of its transmission time” 

“majority of broadcasting time on Icelandic programming or other European programming” 

60% (before 2021, it was 56% in 2020 and 53% in 2019)  

-  Sub-quota for public service provider (RAI): at least half of the transmission time must 

be reserved for works of original Italian expression; 

88 Croatian audiovisual works are defined in Article 2 of the Ordinance of the Electronic Media Council on Croatian Audiovisual Works (5 
January 2023). See under: https://narodne-novine.nn.hr/clanci/sluzbeni/2023_01_3_56.html. 

89 Hungarian work is defined by Article 203 (point 37) of Act CLXXXV of 2010 on Media Services and on the Mass Media (Mttv.). 

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Country 

Quotas for majority proportion of European Works and other sub-quotas for linear services 

-  Sub-quota for commercial service providers: at least one-third must be reserved for 

works of original Italian expression 

Furthermore, between 6pm and 12pm, public service providers must ensure at least 12% of 
their  transmission  time  to  cinematographic  and  audiovisual  works  of  fiction,  animation, 
original documentaries of original Italian expression, wherever produced. 

LI 

LT 

LU 

LV 

MT 

NL 

NO 

PL 

PT 

RO 

SE 

SI 

SK 

(not specified) “majority of broadcasting time” 

(not specified) “more than half of transmission time”  

(not specified) “majority proportion of transmission time” 

At least 51% of weekly transmission time. 

Sub-quotas for national and regional electronic mass media: 

- 

- 

at least 65% of all broadcasts of their own production are in the official language and 
that such broadcasts in the official language would take up at least 65 % of the total 
transmission time 

at  least  40%  of  the  total  transmission  time  of  European  audiovisual  works  of  their 
own production is in the official language 

(not specified) “majority proportion of transmission time” 

At least 50% 

At least 50% 

At least 50% (one-third of this proportion must be reserved for works originally produced in 
Polish language) 

(not specified) “majority proportion of their transmission time” (at least 50% of this proportion 
must be reserved for works originally produced in Portuguese language) 

At least 50% 

At least 50%  

50% of this proportion must be reserved for Swedish  language programmes, programmes 
with Swedish artists active in Sweden and works by Swedish authors active in Sweden 

At least 50% 

(not specified) “majority share of total broadcasting time”  

Article 17 stipulates that at least 10% of transmission time or programming budgets must be reserved 
for  independently  produced  European  works,  including  recent  works  (transmitted  within  five  years  of 
their production). 

In six Member States (BG, FI, HR, HU, IT, SK) the rules regarding the transmission time and/or programming 
budget set quotas higher than 10%90.  

90 In HR, HU and SK the higher quotas apply only to public broadcasters. 

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Furthermore, 12 Member States (BE91, CZ, ES, FI, HR, HU, IT92, NL, PL, PT, SI, SK) have established specific 
sub-quotas for recent works.  

Moreover, three Member States (EE, HR, HU) have established specific rules for national works, by introducing 
a sub-quota for works of original expression of independent producers.  

Additionally, two Member States (BE93, NL) have language sub-quotas for independent works. It should be 
noted that one non-EU EEA country, namely Norway, has a language sub-quota. 

The table below highlights specific rules on quotas and sub-quotas ensuring at least 10% of transmission time 
or alternatively 10% of the programming budget for European works of independent producers in relation to 
linear services. 

Table 10: Level of requirements for Article 17 in Member States and non-EU EEA countries 

Country  Quotas for independent producers and recent works for linear services 

AT 

At least 10% of transmission time or at least 10% of programming budget (“reasonable share of 
this proportion to recent works”) 

BE 

French Community: 

-  At  least  10%  of  transmission  time  for  independent  producers  of  European  works 

(including recent works) 

-  At least 20% of broadcasting time for programmes in the original French language version  

Flemish Community: 

-  At  least  10%  of  transmission  time  or  at  least  10%  of  programming  budget  (“sufficient 

proportion of it must be recent works”) 

German-speaking Community: 

-  At  least  10%  of  transmission  time  or  at  least  10%  of  programming  budget  (“adequate 

proportion of it must be recent works”) 

BG 

CY 

CZ 

DE 

DK 

EE 

At least 12% of transmission time (“adequate share to recent works”) 

At least 10% of transmission time or at least 10% of programming budget (“adequate share of 
this to recent works”) 

At least 10% of transmission time or at least 10% of programming budget (“at least 10% of this 
proportion must be reserved for recent works”) 

Article 17 is not expressly reflected in German law, neither in the form of the broadcasting time-
related  production  quota  nor  in  the  form  of  the  investment-related  quota.  Nevertheless,  the 
majority of German broadcasters already respect the “independent production quota” obligation. 

At least 10% of transmission time or at least 10% of programming budget (“proportionate share 
of this must be reserved for recent works”) 

-  At least 10% of transmission time (including recent works) 

-  At  least  10%  of  monthly  transmission  time  for  own  production  (50%  of  this  proportion 

must be aired during prime time) 

91 French Community. 

92 Although implementing legislation was adopted after the reference period in 2022. 

93 French Community. 

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Country  Quotas for independent producers and recent works for linear services 

EL 

ES 

FI 

FR 

HR 

At least 10% of transmission time 

At least 10% of transmission time (50% of this proportion must be reserved for recent works) 

At least 19% of transmission time or at least 19% of programming budget (50% of this proportion 
must be reserved for recent works) 

Depending on the service, a certain percentage of the contribution to production must take the 
form of investments in independent production 

-  Public  broadcaster  (HRT):  15%  of  programming  budget  to  European  works  of 
independent producers (of this proportion, at least 7.5% for Croatian audiovisual works 
(i.e. works of original Croatian expression) 

-  Private broadcaster: at least 10% of transmission time (at least 50% of this proportion 

must be reserved for recent works) 

HU 

-  At  least 10% of transmission time to  European works of  independent  producers or for 

recent works of independent producers 

-  At least 8% of transmission time for Hungarian works (i.e. works of original Hungarian 

expression) of independent producers or independent producers of recent works 

-  For public broadcaster: more than 15% of annual transmission time for European works 

of independent producers or recent works of independent producers 

IE 

IS 

IT 

LI 

LT 

LU 

LV 

MT 

NL 

At  least  10%  of  transmission  time  of  10%  of  programming  budget  (adequate  share  of  this 
proportion must be reserved for recent works) 

At least 10% of transmission time or 10% of programming budget  

-  For public broadcaster: at least 17% (15% before 2021) of programming budget 

Sub-quota: 7% must be reserved for works of independent producers targeting minors 
and 65% for animation works 

-  For private broadcaster: at least 12.5% (10% before 2021) of programming budget 

Sub-quota: 7% must be reserved for works of independent producers targeting minors 
and 65% for animation works 

At  least  10%  of  transmission  time  of  10%  of  programming  budget  (reasonable  share  of  this 
proportion must be reserved for recent works) 

At least 10% of transmission time 

At least 10% of transmission time (adequate proportion of this must be reserved for recent works) 

At least 10% of transmission time (major proportion of this must be reserved for recent works) 

At least 10% of transmission time or 10% of programming budget (adequate proportion of this 
must be reserved for recent works) 

-  For  public  broadcaster:  at  least  10%  of  programming  budget  for  European  works  of 

independent producers 

Language quota for public broadcaster (since 2021): at least 50% of transmission time 
must be reserved for original Dutch- or Frisian-language productions 

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Country  Quotas for independent producers and recent works for linear services 

-  For private broadcaster:  between 10% and  20%  of  programming budget for European 

works of independent producers 

Language quota for private broadcaster (since 2021): at least 40% of transmission time 
must be reserved for original Dutch- or Frisian-language productions 

NO 

At least 10% of transmission time (appropriate share must be reserved for recent works)  

Specific quota for public broadcaster: such broadcasters must mainly offer content in Norwegian 
language (25% of this proportion must be in the language version ‘nynorsk’) 

PL 

PT 

RO 

SE 

SI 

SK 

At least 10% of transmission time (50% of this proportion must be reserved for recent works) 

At least 10% of transmission time for recent European works of independent producers 

At least 10% of transmission time or at least 10% of programming budget (“adequate share for 
recent works”) 

At least 10% of transmission time or at least 10% of programming budget (“as large a proportion 
as possible for recent works”) 

At least 10% of transmission time (at least 50% of this proportion must be reserved for recent 
works)  

-  Public broadcaster: at  least 15% of transmission time or at least 15%  of programming 

budget (10% of this proportion must be reserved for recent works) 

-  Private broadcaster: at least 10% of transmission time or at least 10% of programming 

budget (10% of this proportion must be reserved for recent works) 

3.2     Overview of financial contributions to the production and the acquisition of rights of 
European works 

This chapter provides an overview of the  countries imposing financial contributions for linear and on-
demand services by the end of the reference period.   

3.2.1     Financial contributions imposed to linear services 

Concerning financial obligations under Article 13(2) of the AVMSD (which concerns both linear and non-linear 
services),  EU  Member  States  and  non-EU  EEA  countries  can  require  media  service  providers  under  their 
jurisdiction to contribute financially to the production of European works, including via direct investment in 
content  and  via  contributions  to  national  funds.  Based  on  this,  they  may  also  require  media  service 
providers  targeting  audiences  in  their  territories,  but  established  in  other  Member  States,  to  make  such 
financial contributions, and these shall be proportionate and non-discriminatory. 

Direct and/or indirect financial contributions94 for linear audiovisual service providers 

Regarding  direct  and/or  indirect  financial  contributions,  16  EU  Member  States  had  no  such 
requirements in place in 2019: AT, BE95, BG, CY, EE, FI, IE, IT, LU, LT, LV, MT, NL, PL, RO, SE. Nor did 
the same Member States reported having in force any direct or indirect financial obligations in either 
2020 or 2021. However, it should be noted that Cyprus and Poland enacted or planned to enact legislative 
measures to enter into force after the reference period to establish direct and/or indirect financial obligations. 

In non-EU EEA countries (IS, LI, NO), no direct and/or  indirect financial contributions were in place and no 
such obligations were introduced in the reference period. 

94 Indirect financial contribution should be understood here as a contribution to national funds. 

95 Flemish Community of Belgium. 

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The  twelve  EU  Member  States  highlighted  below  have  direct  or  indirect  financial  investment 
obligations for linear audiovisual service providers (BE96, CZ, DE, DK, EL, ES, FR, HR, HU, PT, SI, SK):  

− 

− 

In Belgium, in the French Community, any publisher of linear and non-linear television services must 
contribute to the production of  audiovisual works. This contribution takes either  the form of the co-
production or pre-purchase of audiovisual works, or the form of a payment to the film fund of the French 
Community (Centre  du cinéma et de l’audiovisuel). The amount of  the television service  provider’s 
contribution  is  based  on  its  turnover  (e.g.  the  contribution  is  1.8%  of  its  turnover,  if  the  turnover  is 
between  EUR  10  million  and  EUR  15  million).97 Furthermore,  since  2021  a  flat-rate  contribution  is 
provided  for  as  an  alternative,  in  the  absence  of  a  declaration  of  turnover  in  accordance  with  the 
methods  determined  by  the  Government  of  the  French  Community  or  of  data  allowing  it  to  be 
determined. This is aimed at publishers who “would not be cooperative in declaring their turnover or 
would  consider  it  simpler  for  administrative  reasons  to  contribute  under  a  flat-rate  system’. 98 This 
contribution is presumed to amount to EUR 3 million, but this presumption can be reversed. 

In Croatia, all broadcasters are required to contribute to the funding of the Croatian Audiovisual Centre 
(HAVC,  the  strategic  agency  for  the  audiovisual  sector  in  Croatia).  The  amount  of  the  contribution 
represents  a  percentage  of  the  broadcaster’s  turnover.  The  turnover  is  defined  as  the  amount  of 
revenues  (after  deduction  of  transactional  profits,  real  estate  income  and  other  potential  ‘non-
broadcasting’ revenues). The amount due is paid on the basis of invoices issued quarterly by HAVC. 
The following percentages apply depending on the type of broadcaster99:  

o  public broadcaster (HRT): 2%; 

o  private national broadcasters: 0.8%; 

o  private local broadcasters with a reach of more than 750 000 viewers: 0.5%. 

Additionally, in 2019 a levy was in place for cable and satellite operators, amounting to 0.5% of their revenues 
(unchanged  in  2020  and  2021).  Furthermore  in  2019,  operators  of  public  networks,  including  Internet-
connected operators, involved in the distribution of an audiovisual signal (that is IPTV operators) were subject 
to a levy of 0.8% of their revenues.100 This provision was not amended in the reference period. 

− 

− 

In  Czechia,  in  2019,  an  annual  audiovisual  fee  (among  others)  existed  for  television  broadcaster 
operators to be paid to Czech Film Fund. The fee based on the price of the telecast, per received TV 
broadcast is 1%. This obligation did not change in the reference period. 

In Germany, the German Federal Film Board (Filmförderungsanstalt, FFA) is a federal agency under 
public law and Germany’s national film funding body. It is financed by a film levy. The relevant rules 
can be found in the Film Funding Act (FFG)101, in the period from 2017 to 2022 in the FFG 2017, and 
additional agreements of the FFG with – among others – broadcasters. Television broadcasters are 
obliged  to  pay  a  levy,  whereby  the  regulations  distinguish  between  film  levies  of  public  service 
broadcasters102,  broadcasters  of  free-to-air  television  programmes103 and  pay-TV  broadcasters  and 
programme marketers104: 

o  public broadcasters must pay a film levy amounting to 3% of their costs for the broadcasting 
of  cinematographic  works  of  the  penultimate  year,  which  includes  licence  costs,  pro  rata 

96 French Community of Belgium. 

97 All the turnover amount is subject to indexing. 

98 Article 6.1.1 - 1. of Decree of 4 February 2021 on audiovisual media services and video sharing services (Décret du 4 février 2021 
relatif aux services de médias audiovisuels et aux services de partage de vidéos). 

99 Article 25 of Act 61/2018 on Audiovisual Activities (Audiovisual Activities Act) (Zakon o audiovizualnim djelatnostima). 

100 Article 25 of Act 61/2018 on Audiovisual Activities (Audiovisual Activities Act) (Zakon o audiovizualnim djelatnostima). 

101 Act of 23 December 2016 on film funding (Film Funding Act) (Filmförderungsgesetz, FFG). 

102 Article 154 of Act of 23 December 2016 on film funding (Film Funding Act) (Filmförderungsgesetz, FFG). 

103 Article 155 of Act of 23 December 2016 on film funding (Film Funding Act) (Filmförderungsgesetz, FFG). 

104 Article 156 of Act of 23 December 2016 on film funding (Film Funding Act) (Filmförderungsgesetz, FFG). 

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programme  distribution  and  administration  costs,  as  well  as  co-production  contributions  to 
cinematographic works; 

o  commercial  free-to-air  TV  providers  must  pay  a  levy  for  TV  programmes  with  a  share  of 
cinematographic works of at least 2% if their net advertising turnover exceeds EUR 750 000; 

o  pay-TV  broadcasters  must  pay  a  film  levy  amounting  to  0.25%  of  their  net  revenues  from 
subscription  contracts  with  end-consumers  in  Germany  in  the  penultimate  year,  insofar  as 
these revenues do not relate to the provision of technical services and exceed EUR 750 000 
per year. 

German  federal  law,  as  well  as  corresponding  provisions  in  the  laws  of  the  individual  states  (Länder) 
established  the  opportunity  for  public  service  broadcasters  (ARD,  ZDF  and  Deutschlandradio,  as  well  as 
individual public service broadcasters on Länder level) to participate voluntarily in film funding. In addition, on 
Länder  level,  there  are  also  obligations  for  certain  public  broadcasters  to  participate  in  certain  funding  (for 
example, for Westdeutscher Rundfunk in the Film- und Medienstiftung NRW GmbH and for Rundfunk Berlin-
Brandenburg in the film funding by Medienboard Berlin-Brandenburg GmbH). 

− 

− 

In Denmark, in 2019, a direct investment obligation to film funds to promote European works existed 
only for public broadcasters (Danish Broadcasting Corporation and TV 2 Denmark). Changes to the 
amount of the financial contributions were made from 2019, in the framework of the new DR public 
service contract covering the period 2019-2023. 

In France, in 2019, the fund to support cinema and audiovisual media was mainly financed by the tax 
on the price of cinema tickets, by the tax on publishers and distributors of television services, and by 
the tax on video and video-on-demand publishers. The tax on publishers and distributors of television 
services, known as “TST”, contains two parts: 

o  a tax on publishers of television services, which extends a tax introduced in 1986; 

o  a tax on television service distributors, introduced in 2008. 

These provisions were last amended in December 2019, and therefore not during the reference period. 
The  proceeds  of  this  tax  are  allocated  exclusively  to  the  CNC  (French  Film  Fund),  which  is  also 
responsible for its collection and administration. The tax contributes to the CNC’s resources: in 2019 
it generated EUR 492.4 million (including EUR 298.71 million for TST publishers, and EUR 193.71 
million for TST distributors), and financed 72.3% of the support fund. 

− 

In Greece, the 2010 Act on the Reinforcement and Development of Film Art105 introduced requirements 
for financial contributions to the production of Greek audiovisual works, whereby: 

o  Public service media operators must allocate every year 1.5% of their annual turnover to the 
production of cinematographic works that can be regarded as Greek audiovisual works; 

o  Private television stations must allocate every year 1.5% of their annual advertising revenues 
to the production of cinematographic works that meet the requirements of a Greek audiovisual 
work.  The  requirement  in  respect  of  private  television  stations  was  amended  in  2021, 
establishing  an exemption  from the tax on annual advertising revenues for private regional 
digital terrestrial television content providers. 

- 

In Hungary, according to a provision already in force in 2019, a media service provider with significant 
influence  providing  linear  audiovisual  media  services  must  allocate  2.5%  of  its  annual  advertising 
revenues to  the  promotion  of new  Hungarian films. Until 2019, this obligation was to be fulfilled by 
means of a payment to the Media Services Support and Asset Management Fund or by means of a 
financial contribution to a new film production, as agreed between the Fund and the media service 
provider.  The  media  service  provider  can  deduct  the  amount  paid  or  used  for  the  support  from  its 
corporate tax base. Since 2020, following an amendment to the Media Act in 2019 the payment must 
be made to the National Film Institute Non-profit Public Benefit Corporation. 

105 Act 3905/2010 of 2010 on the reinforcement and development of film art. 

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- 

- 

- 

In Spain106, broadcasters with state or regional coverage had to annually contribute to the financing 
of  the  European  production  of  films  and  series  for  television  in  the  reference  period.  The  financial 
contribution was set at 5% of annual income. For publicly owned broadcasters this obligation was 6% 
of the annual income.107 It should be noted that new obligations will enter into force in July 2023108 
The new rules do not change the share of financial contribution (5% of annual income). However, a 
distinction will be introduced between broadcasters with an income equal to or greater than 50 million 
euros and broadcasters with lower incomes (e.g. different quotas which the total financing obligation 
of the broadcaster must respect).  

In Slovenia, the public service media (RTVSLO) shall support Slovenian film production by conducting 
a tender for the funding of film production by independent producers to the minimum amount of 2% of 
the broadcasting fee collected the previous year. 

In  Slovakia  in  2019,  an  obligation  to  pay  a  5%  fee  to  the  Slovak  Audiovisual  Fund  existed  for 
broadcasters  established  by  law,  on  the  basis  of  total  revenues  from  advertising  and  teleshopping 
broadcasting  for  the  last  calendar  year.  This  obligation  did  not  change  in  the  reference  period. 
Furthermore, also in 2019, certain authorised television broadcasters (i.e. a broadcaster with a licence 
whose share of audiovisual works within the programme service in its television broadcasting is more 
than 15% and provides nationwide or multi-regional broadcasting, except if the programme service is 
intended exclusively for its own promotion) were subject to a 2% fee on the basis of total revenues 
from  advertising  and  teleshopping  broadcasting  for  the  last  calendar  year.  The  obligations  of  the 
aforementioned broadcasters did not change in the reference period (2019-2021). 

Out of the above-mentioned Member States with direct or indirect financial contribution obligations, 
two  Member  States  (BE 109,  FR)  applied  financial  contribution  obligations  to  cross-border  linear  service 
providers by 31 December 2021. 

The table below provides an overview of the financial contributions for linear services in force in 2021 in all the 
Member States and non-EU EEA countries, including the alternate obligation to reserve at least 10% of their 
programming budget for European works created by independent producers. The table includes information 
on the existence of a financial obligation for linear services and provides an overview of whether or not existing 
financial obligations are applicable to foreign linear services. The table also summarises the types of financial 
obligations in force in 2021.   

Financial contributions for linear services (countries which impose financial contributions are marked with a V, 
while where there is no obligation, or the obligation does not apply to foreign service providers this is marked 
with an X). 

Table  11:  Overview  of  financial  contributions  for  linear  services  in  force  on  31  December  2021 
(including the alternate obligation to reserve at least 10% of their programming budget for European 
works created by independent producers) 

Is there an 
obligation for 
financial 
contributions 
for linear 
services? 

Does this 
obligation 
apply to 
cross-border 
linear 
services?? 

AT  

BE  

 V 

 V 

 X 

 V 

What is the type of the financial contribution? 

− 

10% of programming budget for European works of independent producers  

−  German  Community:  10%  of  programming  budget  for  European  works  of 

independent producer 

106 The obligation covers non-linear audiovisual service providers as well. 

107 Article 5 of Law 7/2010. 

108 Law 13/2022. 

109 French Community of Belgium. 

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Is there an 
obligation for 
financial 
contributions 
for linear 
services? 

Does this 
obligation 
apply to 
cross-border 
linear 
services?? 

[applies to 
French 
Community] 

BG 

CZ 

CY 

DE  

 X 

 V 

 V 

 V 

DK  

 V 

EE  

EL  

 X 

 V 

 X 

 X 

 X 

 X 

 X 

 X 

X 

ES 

 V 

 X  

FI  

FR  

 V 

 V 

 X 

 V 

HR 

 V 

X 

What is the type of the financial contribution? 

− 

− 

− 

In  the  French  Community:  obligation  to  contribute  to  the  production  of 
audiovisual  works  (in  the  form  of  i)  co-production;  or  ii)  pre-purchase  of 
audiovisual  works;  or  iii)  payment  to  the  film  fund  (Centre  du  cinéma  et  de 
l'audiovisuel) 

 X 

10% of programming budget for European works of independent producers 

Annual  1%  audiovisual  fee  for  Czech  Film  Fund  (based  on  the  price  of  the 
telecast, per received TV broadcasts) 

− 

10% of programming budget for European works of independent producers 

− 

Public broadcasters: levy amounting to 3% of their costs for the broadcasting of 
cinematographic works of the penultimate year 

−  Commercial free-to-air TV broadcasters: min. 2% levy for TV programmes with 
a share of cinematographic works (if net advertising turnover exceeds 750 000 
euro/year) 

− 

− 

− 

− 

− 

− 

− 

Pay-TV  broadcasters:  levy  amounting  to  0.25%  of  net  revenues  from 
subscription contracts with end-consumers in Germany in the penultimate year 
(insofar as these revenues do not relate to the provision of technical services 
and exceed 750 000 euro/year) 

Public  broadcasters:  obligation  to  participate  in  film  funding  at  the  level  of 
German states (Länder) 

10% of programming budget for European works of independent producers 

Public broadcasters: obligation to engage in the production of feature films and 
short and documentary films 

 X 

Public broadcaster: 1.5% annual levy based on annual turnover for the 
production of cinematographic works regarded as Greek audiovisual works; 
Private broadcasters (except private regional digital terrestrial broadcasters): 
1.5% annual levy based on annual advertising revenues for the production of 
cinematographic works regarded as Greek audiovisual works 

Private broadcasters (national and regional): 5% annual levy (based on income 
from  previous  year)  to  contribute  to  the  European  production  of  works  for 
television (e.g., films) 

Public  broadcasters  (national  or  regional):  6%  annual  levy  (based on  income 
from  previous  year)  to  contribute  to  the  European  production  of  works  for 
television (e.g., films) 

− 

19% of programming budget for European works of independent producers 

−  Depending on the service, a percentage of the contribution to production must 

take the form of investments in independent productions 

- 

- 

− 

Levy  on  publishers  of  TV  services  (any  publisher  of  television  services 
established in France that has programmed, during the previous calendar year, 
one or more audiovisual or cinematographic works eligible for financial aid from 
the CNC) 

Levy on distributors of TV services 

Private  broadcasters:  10%  of  programming  budget  for  European  works  of 
independent producers 

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Is there an 
obligation for 
financial 
contributions 
for linear 
services? 

Does this 
obligation 
apply to 
cross-border 
linear 
services?? 

What is the type of the financial contribution? 

HU  

IE  

IT 

IS 

LI 

LT  

LU 

LV  

MT  

NL  

NO 

PL  

PT  

RO  

SE  

SK 

 V 

 V 

 V 

 V 

 V 

 X 

 X 

 X 

 V 

 V 

 X 

 X 

 X 

 V 

 V 

 V 

X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

− 

− 

- 

- 

- 

- 

- 

- 

- 

- 

Public  broadcasters:  15%  of  programming  budget  for  European  works  of 
independent producers 

Levy to contribute to the strategic agency for the audiovisual sector (HAVC): i) 
2% for public broadcaster (HRT); ii) 0.8% private national broadcasters; iii) 0.5% 
for private local broadcasters with a reach of more than 750 000 viewers) 

A levy of 0.5% of their revenues for cable and satellite operators 

A  levy  of  0.8%  of  their  revenues  for  operators  of  public  networks,  including 
Internet-connected  operators,  involved  in  the  distribution  of  an  audiovisual 
signal 

Broadcasters  with  significant  influence:  2.5%  levy  from  annual  advertising 
income to the National Film Institute Non-profit Public Benefit Corporation 

10% of programming budget for European works of independent producers 

Private  broadcasters:  12.5%  of  programming  budget  for  European  works  of 
independent producers (10% up to 2021) 

Public  broadcasters:  17%  programming  budget  for  European  works  of 
independent producers (15% up to 2021)  

10% of programming budget for European works of independent producers 

10% of programming budget for European works of independent producers 

 X 

 X 

 X 

- 

10% of programming budget for European works of independent producers 

-  Min. 10% and max. 20% of the total budget of the national public media service 

(decided by order in council) is spent on European productions  

 X 

 X 

 X 

- 

- 

- 

- 

- 

- 

10% of programming budget for European works of independent producers 

10% of programming budget for European works of independent producers 

Private  broadcasters:  10%  for  private  broadcasters  of  programming  budget 
allocated to European works of independent producers 

Public  broadcasters:  15%  for  public  broadcasters  of  programming  budget 
allocated to European works of independent producers 

5%  levy to  the  Slovak Audiovisual  Fund for  broadcasters  established  by law, 
based on total revenues from advertising and teleshopping broadcasting for the 
last calendar year 

2% levy for certain authorised television broadcasters, based on total revenues 
from advertising and teleshopping broadcasting for the last calendar year 

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Is there an 
obligation for 
financial 
contributions 
for linear 
services? 

Does this 
obligation 
apply to 
cross-border 
linear 
services?? 

What is the type of the financial contribution? 

SI  

 X 

X 

 X 

3.2.2     Financial contributions imposed to on-demand services  

This section provides an overview of the Member States and non-EU EEA countries which impose financial 
contribution requirements for on-demand services based on Article 13(2) of the revised Directive, showing the 
situation which existed on 31 December 2021.  

The table below lists the countries which have imposed financial contribution requirements for VoD services. 
It also specifies whether these obligations were also applicable to non-domestic VoD services and shows the 
type of financial contributions.  Furthermore, the table contains information on whether the obligations listed 
are applicable to cross-border VoDs or not. 

In the table below, the countries which impose financial contributions and where such contributions apply to 
foreign service providers are marked with a V, while where there is no obligation, or the obligation does not 
apply to foreign service providers this is marked with an X.  

Table 12: Financial contributions for on-demand services which existed in the Member States and EEA 
countries on 31 December 2021 

Is there a 
financial 
contribution 
obligation for 
VoD services? 

Is this 
obligation 
applicable 
to cross-
border 
VoDs? 

What is the type of the financial contribution? 

AT  

BE110  

BG 

CZ 

CY 

DE  

DK  

EE  

ES  

EL  

FI  

FR  

 V 

 V 

 X 

 V 

 X 

 V 

 X 

 X 

 V 

 V 

X 

 V 

X 

V 

X 

X 

X 

V 

X 

X 

X 

V 

 X 

 V 

110 In all communities of Belgium. 

- 

- 

- 

- 

Levy  

A levy or obligation to invest directly  

X 

Levy 

VOD services have a choice to replace the European works quota with an 
investment of at least 1% of the total revenues on creation of European 
works or paid acquisition of rights to use European works  

- 

Levy  

X 

X 

X 

- 

- 

Obligation to invest directly 

Obligation to invest directly for domestic while non-domestic VoD services 
have a choice  

X 

- 

Both levy and obligation to invest directly  

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Is there a 
financial 
contribution 
obligation for 
VoD services? 

Is this 
obligation 
applicable 
to cross-
border 
VoDs? 

What is the type of the financial contribution? 

HR 

HU  

IE  

IT 

IS 

LI 

LT  

LU 

LV  

MT  

NL  

NO 

PL  

PT  

RO  

SE  

SK 

SI  

 V 

 X 

 X 

 V 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 V 

 X 

 X 

 X 

 V 

 V 

 V 

 X 

 X 

 V 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 X 

 V 

X 

 X 

 X 

X 

 X 

- 

Direct investment  obligations  (for domestic  and  non-domestic)  and levy 
(only for non-domestic)  

- 

Direct investment obligations  

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

- 

Levy  

                                                 X 

X 

X 

- 

- 

Levy  

Direct  investment  (VoD  services  failing  to  reserve  at  least  10%  of  the 
programmes in their catalogue in an individual calendar year for European 
works  are  subject  to  direct  investment  obligations  of  at  least  1%  of 
revenues to promote European works) 

The table above shows that, on 31 December 2021, 13 Member States had imposed financial obligations 
on the providers of VoD services to promote European works (AT, BE, CZ, DE, EL, ES, FR, HR, IT, PL, 
PT,  SK,  SI).  In  addition,  7  of  these  countries  (BE,  DE,  EL,  FR,  HR,  IT,  PL)  also  imposed  financial 
contribution obligations on cross-border VoD service providers on 31 December 2021.  

Based on the analysis carried out it is possible to distinguish several groups based on the types of financial 
obligations imposed on VoD services (either domestic or cross-border):  

1) 

In five Member States, (AT, CZ, DE, PL, SK), a levy/tax must be paid by VoD service providers. 

2)  There is an obligation to invest directly in European works in Italy, Spain, Croatia (for domestic 
VOD  services)  and  Slovenia  (in  Slovenia,  VoD  services  failing  to  reserve  at  least  10%  of  the 
programmes in their catalogue in an individual calendar year for European works are subject to a direct 
investment obligation of at least 1% of their revenues to promote European works). 

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3) 

In Belgium (in both the French and Dutch-speaking communities) there is a levy OR an obligation (a 
choice) to invest directly. 

4)  Both a levy and an obligation to invest directly exist in France and Croatia (for non-domestic VOD 

service providers). 

5) 

In Greece, there is a direct investment obligation for domestic VoDs. Where non-domestic VoD 
service providers specifically target the audience in Greece, they must contribute financially every year 
1.5%  of  their  turnover  generated  by  their  operations  in  Greece,  either  for  the  production  of  Greek 
audiovisual works or for the acquisition of rights  in Greek audiovisual works that have not yet been 
released, or to a specific fund of the National Centre of Audiovisual Media and Communication S.A.  

6) 

In Czechia, there is a choice for VOD services to replace the European works quota with an investment 
of at least 1% of the total revenues on creation of European works or paid acquisition of rights to use 
European works. 

3.3     Overview of monitoring and evaluation processes with regard to compliance with the national 
measures implementing Articles 13(1), 13(2), 16 and 17 of the AVMSD 

This  chapter  examines  and  details  the  monitoring  and  evaluation  processes  established  by  the  competent 
authorities in EU Member States and non-EU EEA countries to monitor the compliance of linear and non-linear 
services  providers  with  the  obligations  provided  for  in  Articles  13(1),  13(2),  16  and  17  of  the  AVMSD.  In 
particular,  this  chapter  focuses  on  the  methods  and  periodicity  for  the  collection  of  data  by  competent 
authorities, as well as the existence of systems for verifying the veracity of such data (in-house or externalised) 
and the related sanctions for non-compliance. The monitoring and evaluation processes implemented over the 
reference period are also analysed in relation to the situation in 2019.  

3.3.1     Monitoring and evaluation processes in place with regard to compliance with the national 
measures implementing Articles 16 and 17 of the AVMSD  

The monitoring and verification systems of EU Member States and non-EU EEA countries with regard to the 
compliance by linear services providers with the national measures implementing Articles 16 and 17 of the 
AVMSD  are  discussed  in  this  section.  More  specifically,  the  monitoring  practices  and  tools  are  examined, 
taking into account the frequency of monitoring. Additionally, specific existing data verification methods are 
highlighted (including data on specific workforce numbers involved in verification). 

3.3.1.1  Notable  changes  in  the  reference  period  (2020-2021)  regarding  systems  for  monitoring  or 
verifying linear services 

Five Member States (AT, CY, EL, HR, SE) introduced legislative changes aimed at strengthening their 
monitoring or verification systems: 

− 

− 

In Austria, following a change in legislation in 2021, data and percentages per programme must be 
submitted using a specific form by 31 March, and a reason must also be given if the broadcaster fails 
to comply with its obligations. Prior to 2021, a written report had to be forwarded to the authorities by 
31 May, and the law neither required broadcasters to include data and percentages per programme 
on a specific form, nor to explain non-compliance with the criteria set out in Article 16 and Article 17. 

In Croatia, the wording of legislation related to reporting was modified from “shall make best efforts” 
to  “shall  ensure”,  underlying  the  reporting  obligations  of  broadcasters.  In  this  regard,  since  2021, 
reporting obligations must be fulfilled on a specific, more detailed form by 31 January, providing data 
and percentages per programme. Additionally, the verification system was enhanced in 2021 with the 
introduction of on-spot checks on a case-by-case basis (in practice usually every three months). Prior 
to  2021,  the  reporting  deadline  was  31  March,  and  a  written  report  was  sufficient  (without  specific 
information  on  data  and  percentages  per  programme).  Additionally,  on-spot  checks  were  not 
conducted before 2021. 

− 

In Cyprus, a legislative change in 2020 made it mandatory for broadcasters to submit an annual data 
report. Before 2020, no periodicity was defined, but data reports were requested by the Cyprus Radio 
Television Authority (CRTA) on a case-by-case basis. 

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− 

− 

In  Greece,  a  legislative  change  in  2020  strengthened  the  verification  system.  Under  the  new 
legislation 111 ,  the  National  Council  for  Radio  and  Television  (ESR)  receives  data  directly  from 
audiovisual  media  service  providers  (earlier  the  Secretariat  General  for  Communication  and  Media 
collected data and forwarded it to the ESR) and conducts sample-based checks on the data submitted 
by broadcasters (these checks were already conducted by the ESR before 2020). 

In Sweden, a legislative change in 2020 not only modified the periodicity of reporting by broadcasters 
from  biennially  to  annually,  but  also  established  a  specific  digital  form  to  be  used  for  reporting 
purposes. 

Three Member States (LT, PL, PT) made legislative changes in 2021, requiring their competent authorities to 
send  a  report  every  two  years  to  the  European  Commission,  outlining  the  performance  of  broadcasters  in 
fulfilling their obligations pursuant to Article 16 and Article 17. 

The below table provides information on the monitoring and verification processes for linear services in place 
in EU Member States and non-EU EEA countries, and also indicates the periodicity of monitoring.  

Table 13: Monitoring and verification processes for linear services which existed in the Member States 
and EEA countries on 31 December 2021 

Monitoring system 

Periodicity of monitoring 

Verification system 

AT   Report to Austrian 

Communications Authority 
(KommAustria) using a 
specific form 

BE   Flemish Community: Report to 

Flemish Regulator of Media 
using a specific form 

French-speaking Community: 
Report to Conseil Supérieur 
de l’Audiovisuel (CSA) + one-
week samples per quarter 

German-speaking Community: 
Report to Media Council 
(Medienrat der 
Deutschsprachigen 
Gemeinschaft) 

Annual (by 31 March) 

Check (not specified) 

Flemish Community: Annual (by 31 March) 

French-speaking Community: Annual 

German-speaking Community: Annual 

BG  Council of Electronic Media 
requests information 

Case-by-case 

CZ 

Report to Council for Radio 
and Television Broadcasting 

Annual (by 15 January) 

CY  Report to Cyprus Radio 

Annual  

Television Authority (CRTA) 

DE   Report to state media 

Public broadcasting: biennial 

authorities 

Commercial broadcasting: case-by-case 

DK   Report to Danish Radio and 

Biennial112 

Television Board 

111 Law 4779/2021. 

112 Every two years. 

Flemish Community: risk 
analysis + detailed verification 
in case of inconsistencies 

French-speaking Community: 
check + opinion on fulfilment 
of obligations 

German-speaking Community: 
check (not specified) 

Check (not specified) 

Random check of selected 
data (sample-based check) by 
one employee 

Check based on randomly 
selected two-week samples 

Check by the state 
chancelleries of the Länder 
(coordinated by the State 
Chancellery of Rhineland-
Palatinate) 

Check (not specified) 

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Monitoring system 

Periodicity of monitoring 

Verification system 

EE   Report to Consumer 

Protection and Technical 
Regulatory Authority (CPTRA) 

Annual (by 15 February) 

ES   Report to the Spanish National 
Markets and Competition 
Commission (CNMC) 

Annual (by 1 April) 

Check (not specified) by 3 
employees 

Check (not specified) by a 
team of 3 employees + 
assistance by a law firm 

EL   Report to National Council for 

Annual (by 30 June) 

Check (not specified) 

Radio and Television (ESR)  

FI  

Report to Transport and 
Communications Agency 
(Traficom) using a specific 
form 

Biennial 

Check (not specified) 

FR   Report to Regulatory Authority 

Annual 

for Audiovisual and Digital 
Communication (Arcom)  

Check (not specified) by a 
team of six employees + 
fulfilment of quota obligations 
verified by Institut Médiamétrie 

HR  Report to Croatian Agency for 
Electronic Media using a 
specific form + random 
checks 

Annual (by 31 January) 

Random checks/3 months (on average) 

Check (not specified) by a 
team of nine employees 

HU   Report to National Media and 

Infocommunications Authority 
(NMHH) 

Annual 

IE  

Report to Broadcasting 
Authority of Ireland (BAI)113 

Annual 

Report to the Authority for 
Communications Guarantees 
(AGCOM) using a specific 
form + random checks 

Annual 

IT 

IS 

LI 

LT   Report to Lithuanian Radio 
and Television Commission 
(LRTC) 

LU 

Report to Luxembourg 
Independent Authority for 
Audiovisual Media (ALIA) 

Annual 

Annual  

LV   Report to National Electronic 

Annual 

Media Council (NEPLP) + 
random checks 

Check (not specified) 

Check by BAI based on 
randomly selected samples of 
16 weeks 

Check by AGCOM (team of 
three employees) + specialised 
companies 

No verification system in 
place. 

Check (not specified) 

Check (not specified) 

Check by NEPLP based on 
randomly selected samples of 
2 weeks 

Report to Media Commission + 
random checks 

Annual (by 31 March) 

Check by Media Commission 
or accredited body 

No monitoring system in 
place. 

No monitoring system in place.  

113 As of 2023, the staff and responsibilities of BAI have been transferred to Coimisiún na Meán, which is Ireland’s new commission for 
regulating broadcasters and online media. The new state body was established by the Online Safety and Media Regulation Act of 2022. 

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Monitoring system 

Periodicity of monitoring 

Verification system 

MT   Report to Broadcasting 

Annual  

Check (not specified) 

Authority   

NL   Report to Dutch Media 

Public broadcasting: annual (by 1 May) 

Check (not specified) 

Authority   

Commercial broadcasting: biennial (by 1 May) 

NO  Report to Norwegian Media 

Annual  

Authority   

PL   Report to National 

Annual 

Broadcasting Council + 
random checks 

PT   Report to Portuguese 

Quarterly 

Regulatory Authority (ERC) 

RO   Report to National Audiovisual 

Biannual114 

Council  

SE   Report to Swedish Press and 
Broadcasting Authority 

Annual (by 1 March) 

Check (not specified) 

Check (not specified) by one 
employee 

Check (not specified) by one 
employee 

Check (not specified) by a 
team of two employees 

Check (not specified) – 
approximately 15% of 
workforce streamlined 

SK  Broadcasting and 

Case-by-case 

Check (not specified) 

Retransmission Council 
requests information  

SI  

Report to Agency for 
Communication Networks and 
Services (AKOS) using a 
specific form 

Annual (by 28 February) 

Check (not specified) 

3.3.1.2 Monitoring systems in EU Member States 

The  majority  of  EU  Member  States  require  broadcasters  to  submit  an  annual  report  to  their  competent 
authorities on the fulfilment of their obligations under Article 16 and Article 17 of the revised AVMSD (AT, BE, 
CY, CZ, EE, EL, ES, FR, HR, IE, IT, LT, LU, LV, MT, NL115 PL, SE, SI). It should be noted that five Member 
States also carry out random checks throughout the year (BE, HR, IT, LV, PL) to gain up-to-date information 
on compliance with obligations at more regular intervals. Additionally, some Member States have more relaxed 
rules regarding the periodicity of monitoring: four Member States require reports on relevant data every two 
years (DE116, DK, FI, NL117) and three Member States request information on a case-by-case basis, without 
any particular periodicity (BG, DE118, SK). It is to be noted that three Member States have stricter rules than 
other Member States:  

−  Hungary requires broadcasters to send data on a monthly basis (the competent authority examines 

the fulfilment of the year’s obligations annually, on the basis of aggregated data); 

−  Portugal requires broadcasters to report every three months (the competent authority examines the 

fulfilment of the year’s obligations annually; 

−  Romania requests reports twice a year. 

114 Twice a year. 

115 For public broadcasters. 

116 For public broadcasters. 

117 For commercial broadcasters. 

118 For commercial broadcasters. 

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3.3.1.3 Verification systems in EU Member States 

20 Member States (AT, BG, DE, DK, EE, EL, ES, FI, HR, HU, LT, LU, MT, NL, PL, PT, RO, SE, SI, SK) have 
a verification system in place, without however specific procedural rules on verification. In four Member States 
(CY, CZ, IE, LV) data is verified by way of sample-based checks. Accordingly, in these Member States, the 
authority randomly selects samples of data from a certain period to verify data included in reports (e.g., Cyprus 
randomly  selects  two-week  samples).  Moreover,  the  authorities  in  three  Member  States  (ES,  FR,  IT)  use 
external services to assist with the verification process (e.g., the competent authority in Spain is assisted by a 
law  firm,  selected  through  a  public  procurement  process).  In  addition,  the  Flemish-speaking  Community  in 
Belgium applies a risk analysis as part of its verification procedure and conducts a detailed verification in case 
of discrepancies in the data submitted. 

In terms of the number of employees allocated to the verification of data provided by broadcasters, 17 Member 
States (AT, BE, BG, CY, DE, DK, EL, FI, HU, IE, LT, LU, LV, MT, NL, SI, SK) do not have dedicated human 
resources  allocated  to  the  verification  process.  The  remaining  ten  Member  States  have  either  at  least  one 
dedicated employee (CZ, PL, PT) or not more than ten dedicated employees (EE, ES, FR, HR, IT, RO, SE). 

3.3.1.4 Monitoring and verification systems in non-EU EEA countries 

Regarding  the  non-EU  EEA  countries,  Liechtenstein  has  neither  a  monitoring  system,  nor  a  verification 
system. Furthermore, comparing the monitoring and verification systems of Iceland and Norway, the former 
has  stricter  rules,  since  while  Norwegian  legislation  requires  only  an  annual  report  and  checks  incoming 
information,  Iceland  also  conducts  random  checks  on  broadcasters  throughout  the  year  and  involves 
professional  accredited  certification  bodies  in  its  verification  system.  Non-EU  EEA  countries  do  not  have 
dedicated human resources allocated to their verification systems.  

3.3.2     Monitoring and evaluation processes in place with regard to compliance with the national 
measures implementing Article 13 of the AVMSD 

This  section  presents  the  monitoring  and  evaluation  processes  in  place  to  assess  the  compliance  of  VoD 
services providers with the national measures implementing Article 13 of the AVMSD. It highlights in particular 
the similarities and differences with the processes identified in the previous section concerning linear service 
providers. 

3.3.2.1 Monitoring and verification systems related to Article 13 

The monitoring and verification systems in place for ensuring compliance with Article 13 are identical 
or similar in most Member States (AT, BE119, BG, CY, DK, EE, FI, FR, HR, HU, IT, LT, LU, PL, PT, SI, SK, 
SE) to those in place with regard to Article 16 and Article 17, as outlined above. In other words, the way 
in which non-linear audiovisual media service providers are monitored,  and the  methods used to verify the 
data provided do not significantly differ from the methods applied to linear audiovisual service providers. 

In contrast,  in notably five EU Member States (BE120, DE, ES, NL, RO), the monitoring systems for non-
linear service providers differ from the systems applied for linear service providers: 

− 

− 

In the French Community of Belgium, VoD service providers are required to report the number of 
views and rentals of each work in their catalogues for a one-month reference period, also indicating 
the 50 most watched works of the last six months. The competent authority (CSA) analyses the data 
provided (e.g., number of views compared with non-EU films; and/or the position of EU works in the 
ranking of the 50 most watched films). 

In  Germany,  monitoring  of  on-demand  service  providers  was  introduced  in  2021.  Before  that, 
monitoring only existed in relation to checks on the fulfilment of the financial obligations of on-demand 
audiovisual service providers (which included on-site checks carried out by third parties commissioned 
by  the  competent  authority).  Since  2021,  the  monitoring  of  compliance  by  on-demand  service 
providers is carried  out on a case-by-case basis by the Commission on Licensing  and  Supervision 
(ZAK), which is the central body of state media authorities. 

− 

In  Spain,  no  monitoring  system  for  on-demand  service  providers  exists  in  law.  Nevertheless,  the 
Spanish National Markets and Competition Commission (CNMC) has established an administrative 

119 Flemish Community. 

120 French Community. 

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− 

− 

practice,  including  systematic  information  requests  on  an  annual  basis  to  on-demand  audiovisual 
service  providers  established  in  Spain.  In  case  of  need,  on-site  inspections  are  also  conducted  to 
verify information. 

In  the  Netherlands,  in  contrast  with  the  monitoring  of  linear  audiovisual  service  providers,  the 
competent  authority  not  only  requires  data  to  be  reported  annually,  but  also  conducts  additional 
random checks on on-demand service providers throughout the year. 

In  Romania,  on-demand  service  providers  are  required  to  provide  data  quarterly  (the  competent 
authority examines the fulfilment of the year’s obligations annually, on the basis of aggregated data).121 
Furthermore, on-demand service providers are required to submit to the National Audiovisual Council 
of Romania (NAC) a statistical report regarding the percentage and visibility of European works within 
their programme catalogue, for each service and its part.122 This report must be submitted annually.123 

Moreover,  in  the  reference  period,  four  Member  States  (EL124,  IE,  LV,  MT)  did  not  have  a  monitoring 
system in place for non-linear audiovisual service providers. 

Two non-EU EEA countries (LI, NO) did not have a monitoring system for non-linear service providers. In 
Iceland,  the  monitoring  and  verification  system  applied  to  non-linear  audiovisual  service  providers  was 
identical to those in place for linear audiovisual service providers. 

3.3.3     Sanctions for non-compliance with Articles 13(1), 13(2), 16 and 17 of the AVMSD 

The table below provides information on the three most prevalent sanctions for broadcasters and VoD in 
EU Member States and non-EU EEA countries in the event of non-compliance. The three sanctions that are 
usually  applied  in  EU  Member  States  and  non-EU  EEA  countries  are  warnings,  fines  and  licence 
withdrawals.  It  should  be  noted  that  in  some  EU  Member  States,  other  sanctions  are  also  applied  (e.g., 
suspension of licence), but these are not presented in this table. It is to be noted that Latvia is the only Member 
State to have made legislative changes in the reference period with regard to sanctions (in 2021), introducing 
fines as a new category of sanctions. 

Table 14: Most recurring sanctions for broadcasters and VoD in case of non-compliance with Articles 
13(1), 13(2), 16 and 17 in the Member States and EEA countries on 31 December 2021 

Warning 

X 

V 

X 

V 

AT  

BE  

BG 

CZ 

Fine 

V 

V 

Licence withdrawal 

X 

V 

[French-speaking Community: min EUR 250 and max 
3% of annual turnover before tax] 

[not in the German-
speaking Community] 

[Flemish-speaking Community: max EUR 125 000] 

[German-speaking Community: max EUR 25 000] 

V 

[min BGN 3 000 and max BGN 20 000 for 
broadcasters] 

[applies only to broadcasters] 

V 

[min EUR 200 and max EUR 200 000 for broadcasters] 

[min EUR 200 and max EUR 40000 for VoD] 

X 

X 

121 This system was in place in 2019, as well as during the reference period. 

122 Decision 320/2012, article 26, para. (4) 

123 This system was in place both in 2019 and during the reference period. 

124 The implementing ministerial decisions are currently being drafted. 

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Warning 

Fine 

Licence withdrawal 

CY 

DE  

DK  

EE  

ES  

EL  

FI  

FR  

HR 

HU  

IE  

IT 

IS 

LI 

LT  

LU 

LV  

MT  

NL  

NO 

PL  

X 

V 

V 

V  

X 

V 

V 

V 

X 

X 

X 

V 

X 

X 

X 

V 

V 

V 

V 

[applies only to broadcasters] 

V 

X 

X 

X 

V 

V 

X 

V 

V 

V 

[max EUR 30 000 for broadcasters] 

[applies only to broadcasters] 

[applies only to 
broadcasters] 

[min EUR 500 000 and max EUR 1 million] 

V 

V 

V 

V 

V 

[min HKR 100 000 and max HKR 1 million] 

V 

X 

V 

[min EUR 100 000 and max EUR 5 million; or 1% of 
annual turnover, if it exceeds EUR 5 million] 

V 

X 

V 

[min EUR 140 and max EUR 2 000] 

V 

[min EUR 250 and max EUR 50 000] 

[min EUR 50 and max EUR 10 000] 

V 

V 

[max EUR 300 000 for broadcasters] 

[max EUR 34 940 for VoD] 

V 

V 

V 

V 

V 

X 

V 

V 

V 

V 

X 

X 

X 

X 

V 

V 

X 

X 

V 

X 

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PT  

RO  

SE  

SK 

SI  

Warning 

X 

V 

X 

V 

X 

Fine 

V 

[min EUR 7 500 and max EUR 37 500] 

[min RON 5 000 and max RON 100 000] 

V 

V 

V 

[min EUR 165 and max EUR 6 638 for broadcasters] 

[min EUR 165 and max EUR 10000 for VoD] 

[min EUR 1 000 and max EUR 10 000] 

V 

Licence withdrawal 

X 

X 

X 

X 

X 

Sanctions in EU Member States for broadcasters and VoDs 

For linear audiovisual service providers, the most prevalent sanctions in case of non-compliance with Article 
16  and  Article  17  of  the  revised  AVMSD  are  fines,  which  exist  in  the  legislation  of  all  EU  Member  States, 
except for three countries (CY, DE, IE). The range of fines varies between Member States: in some Member 
States the amounts of the fines are small (e.g., LT, SK), while they are significantly higher in others (e.g., ES, 
IT). At this point it should be noted that not all Member States have a specified range of fines. Warnings are 
issued as sanctions in 14 Member States (BE, CZ, DE, DK, EL, FI, FR, IT, LU, LV, MT, NL, RO, SK). The 
most severe sanction, namely the withdrawal of the licence to provide services exists in 12 Member States 
(BE, DE, DK, EE, EL, ES, FR, HR, HU, IE, LU, LV). 

For non-linear audiovisual service providers, the most widely applied sanctions are identical to those applied 
to broadcasters. However, there  are minor divergences in  six Member  States (BG, CZ, EE, MT, NL, SK) 
concerning the application of these types of sanctions compared with those applied to broadcasters. Out of 
these Member States, two (CZ, MT) have lower fines for non-compliance for non-linear audiovisual service 
providers (e.g., in Czechia, the highest fine for on-demand service providers is EUR 40 000), while Slovakia 
applies higher fines (the upper limit is EUR 10 000 instead of EUR 6 638). Furthermore, two Member States 
(EE, NL) apply a narrower set of sanctions for on-demand service providers (e.g. the Netherlands does not 
apply warnings, only fines). It should be noted here that Greece introduced sanctions for non-compliance with 
Article 13 obligations in 2021, which do not differ from those applied for broadcasters. 

Sanctions in non-EU EEA countries for broadcasters and VoD 

Concerning  the  non-EU  EEA  countries,  Liechtenstein  does  not  have  any  sanctions  in  place.  In  Iceland, 
legislation stipulates that fines can be imposed in case of non-compliance. Compared with Iceland, Norway 
has a wider range of sanctions, whereby the competent authority can issue warnings and withdraw the licence 
of a broadcaster if necessary. The sanctions are identical for broadcasters and non-linear audiovisual service 
providers. 

3.4     Data reporting under Articles 13, 16 and 17 of the AVMSD 

For this report, the  national data  monitoring reports  of all Member  States and non-EU  EEA countries were 
collected in light of their reporting obligations pursuant to Articles 13(4) and 16(3) of the AVMSD. This section 
summarises  the  Member  States’  reports  and  non-EU  EEA  countries’  reports  collected.  The  following  sub-
sections provide an overview on the data reported under Articles 13, 16 and 17 of the AVMSD. 

However,  some  clarifications  should  be  mentioned  regarding  the  data  collected  and  the  figures  and  tables 
presented in the sub-sections below: 

−  The German-speaking Community of Belgium did not complete a data monitoring report as the 
only  linear  service  provider  does  not  broadcast  non-domestic  European  works,  but  purely 
local/national  content.  In  addition,  there  is  no  VoD-service  originating  in  the  German-speaking 
Community of Belgium which offers movies or series and/or sales its services.   

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− 

Iceland, Ireland, Latvia, Liechtenstein, Norway and Romania only reported data on the promotion 
and share of European works for linear services for 2020 and 2021. This is explained by the fact that 
in  Ireland  and  Romania,  the  requirements  arising  from  Article  13  of  the  revised  AVMSD  have  only 
been transposed into national legislation after the reference period. Latvia explained that they do not 
currently have data on VoD available because the financial contribution in Latvia is not mandated by 
law. In non-EU EEA countries, the revised AVMSD has still not been transposed into national law and 
countries therefore did not report data required by Article 13(4) of the revised AVMSD. The revised 
AVMSD was only recently incorporated into the EEA Agreement as of 9 December 2022.  

−  The Netherlands reported data for 2020 and, only to the extent that it was available, for 2021. 
This is because national public service broadcasters are required to report on an annual basis. Only 
information  that was already available for 2021 was  reported. The reporting data for calendar year 
2021 (and 2022) will be available in Q4 of 2023. 

−  Poland reported data on the promotion and share  of European works in non-linear services (VoD) 
only  for  2021,  with  the  justification  that  Poland  has  transposed  the  revised  AVMSD  in  the  Polish 
Broadcasting Act amendment of 11 August 2021, which entered into force on 1 November 2021, but 
some of provisions have entered into force only on 1 January 2022. 

−  Portugal’s reported data reflects some of the budgets contained in article 13 of the revised AVMSD, 
yet it is not fully applicable, due to the entry into force of Law n.º 74/2020, of 19 November 2020, which 
only took effect after 17 February 2021. Therefore, since investment data connected to the pertinent 
income  for  2021  may  only  be  collected  until  the  end  of  2022,  the  accessible  data  can  only  be 
concrete in 2022. 

In addition, France and Sweden provided additional explanations in separate documents regarding the data 
supplied, that are also annexed to this report.  

The following sub-sections will: 

−  Summarise the Member States’ and non-EU EEA countries’ reports on the state of implementation of 

Articles 13, 16 and 17 during the reference period (2020-2021) (sub-section 3.4.1    

−  Detail and assess the extent to which Member States have in their national implementations of the 
AVMSD considered the Commission Guidelines on calculation of the share of European works in 
on-demand catalogues and on the definition of low audience and low turnover125 (sub-sections 3.4.7   
3.4.8    

−  Provide concluding remarks on the Member States’ and non-EU EEA countries’ data reporting (sub-

section 3.4.9    

3.4.1    Number of channels covered under Articles 16, 17 of the AVMSD 

In 2020, the total number of linear services was 4397. In the following year (2021), the total number of linear 
services increased slightly to 4483. 

During  the  reference  period  (2020-2021),  the  total  number  of  linear  services  without  exempted  channels 
covered under Articles 16 and 17 of the AVMSD under Member States' and non-EU EEA countries' jurisdictions 
has increased from 2161 in 2020 to 2247 in 2021, as presented in Table 15 below. In 2021, Germany had the 
highest  number  of  linear  services  without  exempted  channels  (531),  followed  by  Czechia  (174),  Romania 
(149), Bulgaria (148) and France (146).  

125 Communication from the Commission Guidelines pursuant to Article 13(7) of the Audiovisual Media Services Directive on the 
calculation of the share of European works in on-demand catalogues and on the definition of low audience and low turnover 2020/C 
223/03; available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?toc=OJ%3AC%3A2020%3A223%3ATOC&uri=uriserv%3AOJ.C_.2020.223.01.0010.01.ENG  

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Table 15 Number of linear services (without exempted channels), period 2020-2021 (Art 16&17) 

600

500

400

300

200

100

0

a
i
r
t
s
u
A

a
i
r
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3.4.2     Application of Article 16 of the AVMSD 

This sub-section provides an overview of the extent to which TV broadcasters appear to reserve a majority 
proportion of the transmission time to European works, as set out in Article 16 of the AVMSD. 

This paragraph gives an overview of the number of channels per Member States and non-EU EEA countries 
reaching the 50% quota of European works in the years of 2020 and 2021. According to the data reported, all 
the Member States appear to reach the quota laid down in Article 16 of AVMSD in the reference period, except 
one Member State (CY), where the majority of linear audiovisual media service providers did not  appear to 
reach  the  obligation  incorporated  in  Article  16  of  AVMSD  throughout  the  reference  period.  It  should  be 
underlined  that  the  level  of  satisfying  the  50%  share  by  linear  audiovisual  media  service  providers  in  12 
Member States (AT, BE126, EE, EL127, ES, FR, HU, MT, PL, RO, SI, SK) and in Norway was high during the 
reference period.  

It should be noted that the data reported on the fulfilment of the share show significant divergences between 
Member States. For example, five Member States (BG, DE, EL, LV, NL128) have reported a very low amount 
of  data  from  broadcasters,  while  other  Member  States  (for  example  Cyprus  and  Estonia)  provided  data 
covering almost all of their linear audiovisual media service providers. Related to that 3 Member States (BE129, 
DK130, IE,131) and Liechtenstein have no data on adherence to the quota laid down in Article 16 of AVMSD. 

Between 2020 and 2021, the proportion of European works in this context has generally either stagnated or 
changed  slightly  (either  a  small  increase  or  decrease  in  compliance)  in  Member  States  and  non-EU  EEA 
countries. However, two Member States (CZ, SE) show remarkable shifts in  reaching the quota. In case of 
Czechia, the reason for this change is due to an expansion of channels covered by data reporting. At the same 
time in Sweden, 11 broadcasters, which were under exemption of compliance with the required quotas for the 

126 French Community and Flemish Community. 

127 The amount of data reported for Greece for the reference period is low. 

128 For the year 2021. 

129 German-speaking Community. 

130 Data provided only on 1 channel. 

131 Ireland provided data for 2020 but not for 2021. 

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year 2020 were not under exemption anymore in 2021. Therefore, these broadcasters were included in the 
calculations and – based on reported data – appeared to have low shares of European works. 

3.4.3     Application of Article 17 of the AVMSD 

This sub-section presents the results achieved as regards European works made by independent producers 
(i.e., "independent productions") as set out in Article 17 of AVMSD. 

Below an overview on the number of channels per Member States and non-EU EEA countries appearing to 
reach the 10% quota of independent works in the years of 2020 and 2021 is provided. Based on data reports, 
the majority of linear audiovisual  media service providers in  all Member States  and  non-EU  EEA countries 
adhere to the obligation laid down in Article 17 regarding independent productions in the reference period. The 
ability of broadcasters to reach the target appears to be particularly high in 15 Member States (AT, BE132, CY, 
DE, EE, EL, ES, FI, HR, HU, IT, MT, PL, RO, SI) and in Norway throughout the reference period. Additionally, 
France shows a high level of adherence from the year 2021. It should be noted that, similarly to the European 
works quota, data reported on the fulfilment of obligations show notable differences between Member States. 
More precisely,  four Member States (DE, EL, LV, NL133) and  Norway have  reported a  low  amount of  data, 
while other Member States (for example AT and EE) shared data on all their channels. 

Furthermore,  four  Member  States  (BE134,  DK,135IE,136 LT)  and  two  non-EU  EEA  countries  (IS,  LI)  have  not 
shared data on compliance with the quota laid down in Article 17 of AVMSD. 

Between  2020  and  2021,  the  proportion  of  independent  productions  in  this  context  has  generally  either 
stagnated  or  changed  slightly  (either  a  small  increase  or  decrease)  in  Member  States  and  non-EU  EEA 
countries. In Sweden, a peak of broadcasters not appearing to reach the target has an identical reason as in 
case of Article 16: broadcasters exempted in 2020 became subject to the obligation under Article 17, but did 
not appear to respect the quota stipulated therein as of 2021. In other Member States (for example in France 
and in Hungary), a stronger adherence to the quota can be detected in 2021 compared to 2020. 

3.4.4     Number or share of exempted channels from the reporting obligations 

The Guidelines for Monitoring the Application of Articles 16 and 17 of the AVMSD137 issued by the Commission 
allowed exemptions from reporting obligations for channels with a very low audience share (below 0.3%). 138. 

The below table presents the number  of exempted channels from the reporting  obligations in the period of 
reference, based on the data reports provided by Member States and non-EU EEA countries, in light of their 
reporting obligations pursuant to Article 16(3) of the AVMSD. The highest number of exempted channels is in 
the Netherlands (410), followed by Hungary (228), and Italy (215). 

Three Member States (EE, LV, MT) in addition to Liechtenstein did not report exempted channels from the 
reporting obligations.  

Table 16 Number of exempted channels from the reporting obligations in the years of 2020-2021 

2020-2021 

Austria 

Belgium (FR) 

34 

11 

132 French Community and Flemish Community. 

133 For the year 2021. 

134 German-speking Community. 

135 Data reported only on 1 channel. 

136 Ireland provided data for 2020 but not for 2021. 

137 European Commission, Revised Guidelines for Monitoring the Application of Articles 16 and 17 of the Audiovisual Media Services 
(AVMS) Directive, 2011, Doc CC AVMSD (2011) 2; available at: https://digital-strategy.ec.europa.eu/en/library/revised-guidelines-
monitoring-application-articles-16-and-17-audiovisual-media-services-avms.  

138 Exemptions to reporting obligations provided for in Article 16(3) of the AVMSD are detailed in section 3 of the above-mentioned 
Guidelines and include, among others, television broadcasts that are intended for local audiences and do not form part of a national 
network" (Article 18 AVMSD). 

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2020-2021 

Belgium (NL) 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Iceland 

Ireland 

Italy 

Latvia 

Liechtenstein 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Norway 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

9 

6 

20 

8 

8 

55 

0 

7 

153 

46 

52 

228 

1 

21 

215 

0 

0 

28 

219 

0 

410 

31 

102 

10 

49 

143 

102 

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Spain 

Sweden 

191 

77 

Source: Member States, data reporting under Articles 16 & 17  

3.4.5     Number of VoD services covered under Article 13 of the AVMSD  

2020-2021 

In 2020, the total number of VoD services was 1950. In the following year (2021), the total number of VoD 
services was 1984, slightly higher than in 2020. 

During  the  reference  period  (2020-2021),  the  total  number  of  VoD  services  without  exempted  channels 
covered by Article 13 of the AVMSD under Member States' and non-EU EEA countries' jurisdictions increased 
mildly from 1410 in 2020 to 1444 in 2021, according to data reports provided by Member States and non-EU 
EEA countries in light of their reporting obligations under Article 13(4) of the AVMSD, as shown in the below 
figure. In 2021, France had the highest number of  VoD providers (without exempted channels) covered  by 
Article 13 (410 in total), followed by Hungary (163), Czechia (121), Slovakia (97) and Austria (85). 

Figure 2 Number of  VoD services under Article 13 (withour exempted channels) 

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3.4.6     Application of Article 13 of the AVMSD 

This sub-section provides an overview of application per Member State and non-EU EEA countries regarding 
the obligation for VoD providers set out in Article 13 of the AVMSD to secure at least a 30 % share of European 
works in their catalogues and ensure prominence of those worksin the years of 2020 and 2021. 

Of all countries and although nine Member States did not report data  under Article 13, it appears that VoD 
providers in five Member States (BE, FI, HU, IT and SE) adhered fully to the EU quota to secure at least a 
30% share of European works in their catalogues and ensure prominence of those works for both years of 
reference (2020 and 2021). Overall, in a large number of Member States (AT, BG, CY, EE, ES, EL, FR, HR, 
LU, PT, SI, SK), the level of European works in this context is quite high as almost all VoD providers appeared 
to have fulfilled the EU quota, with the exception of four or fewer VoD providers not appearing to reach the EU 
quota  in  each  of  those  Member  States  for  either  of  the  reference  years.  However,  the  level  of  adherence 
appears slightly lower in 3 Member States (CZ, DE and NL).  

3.4.7     The Commission Guidelines on the calculation of the share of European works in on-demand 
catalogues and on the definition of low audience and low turnover 

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It must be addressed separately to what extent the indications about calculating what constitutes a 30% share 
in a VoD catalogue have been considered and to what extent the approach to the criteria “low turnover” and 
“low  audience  share”  justifying  an  exemption  from  the  obligations  were  included  in  the  national  legal 
framework.  As  will  be  shown,  how  the  “incorporation”  of  the  Commission  Guidelines  has  taken  place,  can 
range from explicitly mentioning the Guidelines in the actual legislative text to simply considering them 
in the monitoring and supervision when checking for compliance of the providers with the (national) 
laws’ provisions.   

Concerning  the  methods  of  calculation  for  the  share  of  European  works,  the  Guidelines  suggest  a 
calculation  per  title,  giving  some  additional  criteria  for  what  should  be  considered  a  “title”.  In  addition,  the 
Guidelines underline that, in case of multiple national catalogues offered by one provider, the calculation has 
to be done for each of them separately (and the share reached for each of them too). As a further point, the 
Guidelines include considerations on the temporal dimension (at which point in time the compliance with the 
30 % share should be ensured) but leave it open which method should used between, compliance at any given 
time when it is checked or compliance on average within a pre-determined period.  

Concerning the criteria suggested in the Guidelines for use to determine whether a service provider should 
be exempted for only having low turnover or for having low audience, there are a few points to be mentioned. 
The criteria shall in principle be used both for providers exempted from their obligation to have the catalogue 
share according to Art. 13(1) AVMSD and for possible financial contribution obligations according to Art. 13(2) 
AVMSD. This also includes those services established in another Member State but targeting audiences in 
their territories, which can be both broadcasting or video on demand services. For turnover, the Commission 
Guidelines refer to the relevant Recommendation 2003/361/EC, which suggests relying on the EUR 2 million 
annual turnover threshold mentioned therein. Nevertheless, Member States with smaller national audiovisual 
markets can determine lower turnover thresholds. For low audience, the threshold is an audience share of less 
than 1% share for non-linear services and of 2% in a given targeted Member State for linear services.   

The following analysis will be focused only on a few of the elements of the Guidelines, e.g., the question of 
exempted services in the case of requiring targeting services to contribute financially, too, can only become 
relevant if there is a system in place of also obliging non-domestic providers. Or the question of the temporal 
dimension in the case of the calculation of catalogue share leaves discretion to the Member States, which is 
why this is not an element which is reported in detail about.  

The following parts will therefore present first the methods of calculation of the 30%, namely whether title- 
or time-based and whether there is any specific observation for some Member States. They will then add some 
information on additional aspects of the catalogue shares. After that there will be a part on the application 
of the exemption criteria before there is a concluding overview.  

3.4.8     Relevance of the Guidelines in practice  

As  a  reminder,  the  following  assessment  concerns  the  reference  period  2020-2021.  The  deadline  for 
transposition  of  the  revised  AVMSD  was  19  September  2020  and  a  significant  number  of  Member  States 
transposed the Directive after that date or at least very late during the reference period. The Guidelines were 
published  on  2  July  2020,  which  is  why  the  few  Member  States  that  had  already  transposed  the  Directive 
before  that  time  could  not  have  explicitly  incorporated  the  Guidelines  in  the  transposing  legislation.  This 
affected 4 Member States (BE139, DK, HU and PT140)141. There were no comparable rules as the ones included 
in the Guidelines before. The following analysis will take stock of how the rules of the AVMSD in that context 
are being applied in practice.  

The analysis is based on the information provided for in the reports of the Member States and the country 
experts’ input to the desk research on the Member States. Beyond the Member States of the EU, those of the 
non-EU EEA countries are considered, but for those, the inclusion of the AVMSD in the EEA Agreement came 
after the reference period.  

Not all Member States will be mentioned for each of the points in the following because they may not have any 
corresponding rules in place (or not yet) for one of the aspects. However, to give a more complete picture, 

139 Only the Flemish-speaking community  

140 For Portugal, the draft bill was approved by the Portuguese Parliament in July 2020, although it was finally adopted later in 2020. 

141 According to European Audiovisual Observatory Home, Revised AVMSD Tracking Table; available at: 
https://www.obs.coe.int/en/web/observatoire/avmsd-tracking  

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partly  the  rules,  which  were  prepared  but  only  entered  into  force  after  the  reference  period,  will  be  briefly 
mentioned.  

Of the countries covered, it should be noted that a relevant part of them did not only refer in accompanying 
documents  to  the  Guidelines  or  include  the  main  elements  of  the  Guidelines  in  the  law,  but  they  actually 
included an explicit mention of or reference to the Guidelines in specific provisions of the law. This is 
the case, for example, in Austria, Bulgaria, Croatia, Greece, Hungary, Latvia, Luxembourg and Portugal. 
For a (large) number of  Member  States, the laws changed  after the reference period and now also have 
explicit  references  such  as  in  Poland,  Romania,  Slovakia,  Slovenia.  Yet  others  have  included  the 
Guidelines in the secondary law based on the statutory law, e.g. in Statutes of Regulatory Authorities, such 
as in Germany. Even where there is no reference as such, based on the information received, the transposition 
solutions  as  reported  or  the  application  in  practice  confirms  that  the  approach  of  the  Guidelines  is  being 
considered, for instance,  in Cyprus, Finland, France and the Netherlands.  In some cases, the situation 
concerning the reference period is not entirely clear, which is either because the transposition of the Directive 
had not taken place and therefore no information was provided in the country files, or because new rules were 
still in preparation, for example, secondary rules in by-laws or Guidelines of the competent authorities that deal 
with the matter.   

This is, for example, the case for some aspects in the Belgium communities, where the laws for each of the 
regions regulate the exceptions without referring to the Guidelines, but confer the possibility for further detailing 
to the authorities. The situation is similar for Malta142 and Denmark. In the latter, national guidelines being in 
preparation indicate a reliance on the Commission Guidelines. Also in the Czech Republic, the previous law 
was still in place and it was not yet clear how possible national guidelines would relate to the Commission 
Guidelines. 

Similarly, for the non-EU EEA Member States, there was also no transposition yet during the reference period. 
Still,  Iceland  and  Norway’s  drafts  of  the  implementation  include  either  a  reference  to  the  Commission 
Guidelines or the authority, which will be given the power to lay down its Guidelines, has indicated that the 
Commission Guidelines shall be the basis.  

Finally, it should be noted that for Ireland, the transposition of the revised AVMSD did not occur during the 
reference period, so no development existed regarding the Guidelines. 

Share of European works in VoD catalogues 

For the first overview, most Member States have solutions in place that – even if not yet in the reference period 
– in the future will rely on title-based calculations for the catalogue share in VoD service providers’ catalogues. 
Partly, this was not the case in the past for those Member States that already had obligations with concrete 
shares  in  catalogues  before  the  new  AVMSD  was  transposed  or  even  the  Commission  Guidelines  were 
adopted. The following overview gives more insights into the different approaches. 

In Austria, relying expressly on the Guidelines, the calculation aligns with the Guidelines by being based on 
titles. As is laid down in the Regulation of the regulatory authority, it is titles per year and, e.g. in a series of 
films, each film, but in a season that is calculated as one title, except if the individual episodes of the season 
justify regarding them as an individual title, and thereby in the same way as in the Guidelines. The Bulgarian 
law also refers to the average annual basis of the number of titles in the service catalogue at the same time, 
the regulatory authority shall adopt more detailed rules on the relative weighting of the individual types of titles 
such as e.g. the episodes question.  

In the Member States where the previous law was still in place, e.g. in Cyprus, there was a lower catalogue 
share, but also based on titles, and the number had to be achieved at any given time. In the Czech Republic, 
it was similar with a lower number. Denmark relies on a per-title calculation, as is the case for Estonia after 
the reference period of this report, and the title count has to apply for each catalogue. For France, there is a 
reliance on the calculation per title model, too.  Germany is among those Member States that have directly 
used the Commission’s guidelines as a basis for the legislative rules on European works, as laid down in the 
Statute  of the regulatory authorities and therefore relies on  a  per title calculation, in that case, based  on  a 
reference period of six months.   

Luxembourg implemented the Commission Guidelines directly and explicitly for some of the criteria. Still, the 
way the law is drafted, it relies on the standards of the Guidelines for all of the elements, so while certain terms 

142 However, after consultation, the Maltese authorities highlighted that the shares of Europeans Works are calculated per titles.  

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such as low turnover and audience share are directly included in the context of the amendment, the Guidelines 
also serve as the basis when it comes to calculation of catalogue share requirements.  

While in Italy the calculation was based on the “airtime “of the content in the catalogues in the past, it will be 
title-based  since  the  new  rules  came  into  force  after  the  reference  period,  and  the  regulatory  authority  still 
needs to lay down the details in a regulation.  

Since the updating of the rules also in the Netherlands, there is a title-based calculation, same in Portugal, 
Slovenia, Romania and Sweden. Greece and Poland are further examples of a shift from the duration of the 
titles and time of availability in the catalogues to title per quarter of year-calculation. 

For Hungary during the reference period, the calculation relies on an aggregated total length of programmes 
made available in a given calendar year in the programme schedule of on-demand audiovisual media services 
and each title’s length is counted once for the calculation.  

Exemptions  

There  is  a  similar  observation  to  be  made  as  above  when  considering  the  national  approaches  to  the 
exemptions that need to be applied after the 2018 revision of the AVMSD. Since in many countries there were 
no rules on catalogue shares, for example, there was also no need to even consider whether there would be 
exemptions  in  place  for  certain  types  of  providers.  Even  where  rules  existed,  these  were  not  necessarily 
applicable in a cross-border dimension. In those cases, where already during the reference period rules about 
exemptions from the obligations were put in place, they follow the approach of the Guidelines. Of the different 
types of exemptions foreseen, the one that has been implemented and applied the most in absolute numbers 
across the countries is the exemption that results from the nature of the services concerned. 

In Austria, for example, audience share is based  on sales of service of  a provider to  establish the  market 
share. Exemptions are often in practice based on the genre of the service. Details on the calculation are – as 
is also the case for many Member States – to be found in a regulation by the regulatory authority. This is also 
the case for Germany where the statutes on the matter go into exact details on how to apply the calculation 
for  different  types  of  services  as  well  as  the  criteria  to  decide  whether  the  nature  of  the  service  justifies 
exemptions.  

For the Flemish community of Belgium, there is an example of a different approach to turnover based on 
the size of the market, the threshold being EUR 500 000. An additional exemption exists in the sense that if 
investments are already made via the linear service of a provider, then that provider can be exempted for the 
obligations in non-linear services and vice-versa. In Croatia, the audience share to be used is 0.3.% or less 
of total audience share. In Estonia, for future reporting periods, exemptions are based on fulfilling at least one 
of three criteria for VoDs: less than ten employees per financial year plus less than 2 million Euro turnover, 
less than 1% audience share, and thematic catalogues.  

Many  States  use  both  “low”  criteria,  although  it  seems  that  the  application  of  the  low  turnover  criteria  is 
regarded as being more easily applicable. As mentioned, for many states, more details will only be clear in the 
future; for example, in Greece there is a reference to the Guidelines for the two low criteria, but nonetheless 
details on their application will be laid down in a ministerial decision. Others have done so already, such as 
Hungary.  

For the non-EU EEA countries, the main reliance in future seems to be low turnover, e.g., for Iceland, the draft 
includes a threshold of below EUR 680 000.  

Poland relies on the low audience share of the same number of 1% as in the Guidelines. It refers to subscribers 
of “data transmission services” in the previous year; that data for calculation is provided by another regulatory 
authority than the media regulatory authority. While  Slovakia, under the old rules, relied more generally on 
establishing  the  “economic  situation”  of  the  provider  to  decide  about  possible  exemptions,  Sweden  gives 
numbers based on its national currency (below 20 Mio SEK) and for the 1% criteria bases this on viewing time 
of the catalogues.  

These are only examples showing that, in general, where already applicable, the calculations follow for low 
turnover the Commission Guidelines and for audience share, but for the latter with some variations in terms of 
the  number  or  the  way  it  is  assessed.  Mostly,  genre-based  exemptions  and  low  turnover  exemptions  are 
applied in practice. 

3.4.9     Conclusion on data reporting 

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In observing the data input from the concerned reporting period, it is clear that this is a transitional period. A 
large part of Member States had not yet transposed the revised AVMSD. In the cases where the (statutory) 
laws already reflected the new provisions, these still had to be concretised in secondary law (such as decrees) 
or by-laws by regulatory authorities, which was a process still underway during the reference period. Therefore, 
even with a transposition completed by the legislator in the reference period, this does not mean that the actual 
details  of  the  application  of  the  rules  in  question  here  were  already  clear,  because  the  second  step  of 
implementation was still taking place. In addition, the obligation for the providers to comply with the (new) rules 
often  only  started  to  apply  for  the  period  after  the  end  of  the  current  reference  period,  due  to  the  late 
transposition of the Directive and the rules only becoming applicable after entry into force of the law, e.g. where 
calculated for an annual period the first calculation period would only start at the beginning of the following 
year.  In  order  to  better  indicate  the  role  that  the  Guidelines  are/will  be  playing,  the  overview  also  includes 
changes which only took place after the reference period, to the extent that this information was available from 
the information collected. This clearly shows a high level of similarity of calculation approaches and exemptions 
and an alignment with the Commission Guidelines. This is true not only for the cases where the Guidelines 
have been referenced in the wording of the laws, but where it is a regulatory practice that the details on how 
to assess providers' compliance by the regulatory authorities use the indications from the Guidelines. A full 
picture will only be possible in the reporting about the next reference period, during which the new rules  are 
expected to be applied to all providers in all Member States, so that an overall comparison would be available. 

3.5     Stakeholder views on the implementation of Articles 13, 16 and 17 

Article 13 

The associations representing producers and distributors are generally positive about this article as, in their 
view, it contributes to the promotion of  national content and has led to an increased level of local investment, 
either through direct investments or levies. These associations also say that they are in favour of the quota 
being even higher than 30%. 

An association representing producers  is extremely satisfied with Article 13(1) and would have even preferred 
higher quotas/requirements. At the same time, when giving its view on Article 13(2), the association considers 
that it ensures the sustainability of the financing of independent creations. Since Germany and France had 
already implemented the financial obligations locally before the Directive, the AVMSD imposes obligations on 
the major US streamers and has brought them to the same level as domestic players. Now with the Directive, 
in total 16 countries have introduced such a system according to stakeholders, which has brought about many 
developments domestically. It has encouraged US streamers to invest locally and has led to more investment 
being targeted towards independent productions. The stakeholders consider that this has led to an increase 
in European productions. 

According to an association representing producers and distributors, Article 13 has put VoD services on the 
same level as broadcasters. The association also points out that the move of VoD services towards unscripted 
works poses a threat to producers. According to them, the 30% quota mitigates this threat as it encourages 
VoD  services  to  promote  works  that  take  risks  and  that  fulfil  the  cultural  diversity  target.  The  association 
mentions that the definition of a “European work” is unclear, since each country uses a different one. Therefore, 
in some cases, the authorities cannot check if a work defined as European conforms to their own definition of 
a European work, and in most cases, this label is self-declared by the VoD platforms. 

Associations representing producers and distributors also claim that the implementation of Article 13(2) is quite 
challenging. The cross-border financial contributions to the production of European works, whether via direct 
investment in content or contribution to national funds, lhave created a fragmented situation for pan-European 
VoD services that operate in multiple countries. They are faced with increased costs and an increase in market 
friction. This is concerning especially since most of the big VoD services are US companies. Therefore, while 
there has been an increase in European productions, the quality of the productions is something that is not 
controlled.  

An  association  representing  producers  made  a  particularly  important  point  on  Article  13,  saying  that  it  is 
important not just to have European content on VoD services, but also to promote it. This is because a lot of 
large services promote their own content; therefore, carrying European content without making it visible and 
prominent makes no difference.  

An association representing non-linear media providers does not have an issue with the Article, since more 
than 60% of the content and portfolio of European independent VoD services consists of European audiovisual 
works, which is double the requirement. Therefore, these changes have not impacted the activity of European 
non-linear services. With this in mind, they are of the view that the Commission should encourage an increase 

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in non-national content on VoD services to promote the representation of works from other European countries. 
This would encourage diversity and improve European works and creativity in the industry. 

At  the  same  time,  an  association  representing  linear  broadcasters  and  VoD  services  considers  that 
investments should be driven by European demand rather than quotas. In their view, the quotas have taken 
away commercial freedom and have led to administrative burdens which have caused inflationary mechanisms 
in the sector. This leads to difficulties in acquiring talent and booking local facilities and crews. Ultimately,  in 
their view it has contributed to a decrease in the industry’s competitiveness, which has impacted both VoD 
services  and  local  broadcasters,  that  are  now  faced  with  increased  costs.  Additionally,  VoD  services  are 
investing in their country of origin by means of commissioning. This leads to creative culture being lost while 
independent producers lose the intellectual rights to their productions. 

Article 16 

The associations interviewed have mixed views on Article 16. An association representing producers finds that 
Article  has  not  had  a  great  impact  by  itself  and  that  the  changes  occurring  in  the  market  are  due  to  the 
emergence of VoD platforms rather than regulation. On another note, an association representing producers 
and distributors highlighted that Article 16 is more restrictive on the definition of European works than Article 
13, which is important and appreciated. This is because the article does not  take into account news, sports 
events, advertising, etc. The associations also call for more monitoring of compliance with the Directive. 

Some associations representing producers also want better monitoring of compliance with this Article, claiming 
that some countries do not make it a priority. This is a problem because it makes broadcasters more reluctant 
to comply when they feel that they are facing unfair competition from those that do not comply. 

An association representing linear broadcasters and VoD services points out that the Article would need to 
cater for changes in the market, such as the rise of large VoD services, that are seen as draining broadcaster 
revenues. Another association representing non-linear media providers remarks Article 16 positively since it 
puts broadcasters and VoD services on the same level. On the other hand, an association representing linear 
and non-linear media providers considers that this article has created an additional burden on broadcasters 
over time. This is because while they have had to increase investments in local works and face higher costs, 
consumers  are  increasingly  moving  towards  VoD  services  and  high-end  fiction,  leading  to  a  decline  in 
broadcaster revenues. 

In response, broadcasters have been producing more content jointly. The side-effect of this is a concentration 
of budgets on similar types of works. Since public broadcasters are more focused on their territories than VoD 
services, their audiences are not as wide as those of VoD services. Joint productions therefore enable them 
to raise enough resources to compete with big players in the VoD market. As a result, broadcasters typically 
either go into big productions with concentrated investments or turn towards unscripted works that help them 
manage costs and are easier to sell to advertisers.  

Article 17 

Partly due to this Article having remained unchanged in the revision of the Directive, many associations choose 
not to comment on it, but those that do presented some negative elements in general. 

An  association  representing  producers  and  distributors  points  out  that  there  is  no  clear  definition  of 
independent production, although this is something that might not be appropriate, as it depends on the local 
market. The association therefore proposes that certain criteria should be included in the Article, ensuring that 
the executive producer is independent from a broadcaster at every stage of the production process. Another 
association representing producers would favour an increase in this 10% quota. 

An association representing linear and non-linear services claims that the  Article represents a limitation on 
business and commercial freedom, in addition to forcing control of broadcaster content.  

Another  association  representing  linear  and  non-linear  services  points  out  issues  with  the  sub-quota  on 
independent  production,  particularly  in  France,  because  it  means  that  a  production  arm  that  can  act 
independently but is affiliated to a broadcaster can be at a disadvantage, in comparison with other non-affiliated 
players. This creates frustration among broadcasters and VoD services which feel that their production arms 
have the dice stacked against them. 

Fulfilment of quotas  

Here, all associations representing producers and/or distributors note that, while on average the quotas are 
fulfilled, there are several issues to be highlighted. An association representing producers pointed to significant 
discrepancies  between  countries.  While  big  VoD  services  may  not  fulfil  the  quotas  in  smaller  European 

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countries, the number of European works may exceed the quota in large countries. A further issue mentioned 
is that these quotas include unscripted content. Another association representing producers and distributors 
noted a problem with the lack of a harmonised definition of “European work”, mentioning that while many US-
UK productions are classified within the quotas, they consider that they should not be classified as European 
works. In their view, this highlights the need for a harmonised definition.  

Moreover, they also mentioned a lack of control over the fulfilment of the quotas, as a simple declaration by 
the media provider to the national regulatory authority is currently sufficient. Several associations representing 
producers and distributors called for measures other than simply self-declaration to test the fulfilment of the 
quotas.  

When talking about factors that prevent the fulfilment of the quotas, an association representing producers and 
distributors mentions that the producers that create the content do not have access to data from non-linear 
services and, therefore, do not know if the quotas are fulfilled.  

An association representing non-linear media services points out that big VoD services already produce their 
own content  and do  not want  to invest in third-party  content. These  articles have therefore been helpful  in 
promoting  local  content  on  these  services.Another  association  representing  linear  and  non-linear  media 
providers states that having a large catalogue can make it difficult for VoD services to meet the target quota. 
This is because their two options in such a case are to either invest in enough works to be able to meet the 
quota – which might not be possible at once – or to remove non-European works from their offering, which 
would be detrimental to consumers.  

Furthermore, an association representing non-linear media providers considers that VoD services that do not 
comply with the quotas should be fined, and that the money should be re-invested in local content. However, 
an association representing producers believes that fining big VoD services would not impact them significantly 
given their size. 

AVMSD Guidelines 

Generally,  there  are  no  specific  views  on  the  calculation  methods,  and  they  seem  rational  to  associations 
representing various players as they offer the best approach currently available. However, the problem pointed 
out by associations representing  all players across the audiovisual value chain, i.e., producers, distributors, 
broadcasters, and VoD services, lies with the implementation and application of the Guidelines. 

An association representing producers and distributors finds that the Guidelines create an equilibrium between 
films  and  series,  which  it  considers  very  positive.  Lastly,  an  association  representing  non-linear  media 
providers considers that UK content should not be classified as European.  

A concern expressed by an association representing linear and non-linear media providers is that the level of 
turnover indicated in the Guidelines is very low in their view, given the set-up cost of such a service. It claims 
that, while the level of turnover was supposed to create a cut-off point, it is set so low that it applies to everyone. 
In this sense, it pointed out that implementation of the Guidelines across the Member States will be weak if the 
Guidelines themselves are weak.  

3.6     Conclusions  

On 28 November 2018, the 2018 Directive amending the 2010 AVMS Directive143, was published in the Official 
Journal  of  the  European  Union.  The  revised  Directive  aimed  to  address  and  adapt  to  the  current  media 
landscape and changing market realities.  EU Member States were required to transpose the new Directive 
into national legislation by 19 September 2020. 

Increased  obligations  to  promote  European  works  for  on-demand  services  were  therefore  of  particular 
importance for this study after the adoption of the revised AVMSD. In 2019, most EU Member States were in 
the process of transposing the revised  AVMSD. Few  Member States had implemented  Article  13  in a very 
detailed way. 

143 Directive 2010/13/EU of the European Parliament and of the Council of 10 March 2010 on the coordination of certain provisions laid 
down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services, OJ L 95, 
15.4.2010, p. 1–24 as amended by Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 
amending Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation or administrative action in Member 
States concerning the provision of audiovisual media services (see at: https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX%3A32010L0013)  

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National implementation measures to transpose Article 13 of the revised AVMSD into national law were 
introduced in 17 Member States during the reference period (2020-2021) and in ten EU Member States after 
the reference period.  Only Iceland and Norway did not introduce any national implementation  measures to 
transpose Articles 13(1) and 13(2) of the revised AVMSD into national law over the reference period, but it 
should  be  noted  that  the  revised  AVMSD  was  only  recently  incorporated  into  the  EEA  Agreement  as  of  9 
December 2022. In the case of Articles 16 and 17, legislative changes have been made in a handful of EU 
Member States, four and five respectively. However, most national legislative changes related to Articles 16 
and 17 were minor or of a technical in nature. 

Regarding direct and/or indirect financial contributions for linear audiovisual service providers, 18 EU 
Member States had no such requirements in place in 2019 according to the Study on the period 2015-2019144, 
and the situation remained unchanged over the reference period. In addition, while the AVMSD encourages 
countries  to  promote  co-produced  European  works  or  European  works  of  non-domestic  origin 145,  seven 
Member  States  applied  financial  contribution  obligations  to  cross-border  linear  service  providers  on  31 
December 2021.  

On-demand service providers were subject to financial contributions (levies or investment commitments) in 
only ten Member States in 2019. The present analysis reveals that by 31 December 2021, 14 Member States 
had imposed financial obligations on VoD service providers to promote European works, with Austria, Poland, 
Slovakia  and  Sweden  introducing  new  obligations  during  the  reference  period.  In  addition,  12  of  these 
countries also applied financial contribution obligations to cross-border VoD service providers on 31 December 
2021.  

In relation to monitoring and verifications systems in place, the Study of the period 2015-2019146 indicated 
that a significant number of Member States implemented neither a monitoring system for the implementation 
of Article 13(1) nor a verification mechanism for the data provided by operators. During the reference period 
analysed, only four Member States reported that they did not have a monitoring system in place for non-linear 
audiovisual service providers, which means that a majority of Member States have implemented monitoring 
and verifications processes in 2020-2021. In most cases though, monitoring and verifications systems in place 
for ensuring compliance with Article 13 are aligned with systems in place to monitor linear service providers in 
accordance with Article 16 and Article 17. Furthermore, in terms of sanctions in case of non-compliance, 
there are three typical sanctions applied for non-compliance with the obligations laid down in Article 13, Article 
16  and  Article  17:  warnings,  fines  and  licence  withdrawals.  These  types  of  sanctions  on  broadcasters  and 
VoDs differ only slightly between Member States. 

Lastly, the reference period examined appears to be a transitional period, according to the analysis of  data 
reported  under  Articles  13(1),  13(2),  16  and  17  of  the  AVMSD,  including  on  the  application  of  the 
Commission Guidelines, as noted in section 3.4.9   data about the implementation of Article 13. 

Concerning the application of the Commission Guidelines, most Member States had not yet started to apply 
those provisions in the reference period, even if they had been transposed and even if the Guidelines of the 
Commission were explicitly referenced. This is partly also because where new laws were in place, these still 
needed to be concretised in secondary law (such as decrees) or by-laws by regulatory authorities, which was 
a  process  still  underway  during  the  reference  periodor  thereafter.  Nonetheless,  a  high  level  of  similarity  in 
calculation  approaches  and  exemption  applications  with  the  indications  contained  in  the  Commission 
guidelines can be observed across the EU Member States with few specific solutions e.g., concerning the level 
of thresholds, which also reflect the possibility mentioned in the Guidelines to adapt the figures according to 
the special situation of national markets.  

144 https://digital-strategy.ec.europa.eu/en/library/commission-reports-promotion-european-works-audiovisual-media-
services?pk_source=ec_newsroom&pk_medium=email&pk_campaign=Shaping%20Europe%E2%80%99s%20Digital%20Future 

145 AVMSD, recital 70 

146 Ibid.  

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4.  Volume 2: The market for audiovisual 
works 

This chapter describes and analyses the market for audiovisual works. It covers the following aspects: 

-  The size of the audiovisual market: the report provides an overview of the audiovisual market based 
on  the  number  of  companies  in  the  relevant  sectors,  the  revenues  of  companies  operating  in  the 
audiovisual sector and employment data. As Eurostat data for the reference period is not available 
(the latest data is from 2019 and 2020), the report bases its results on the Orbis Europe data. 

-  Business  models  in  the  audiovisual  sector:  the  analysis  seeks  to  investigate  how  ownership, 
revenue  models  and  geographical  footprint  are  combined  into  different  business  models  of  VoD 
services and how widespread these models are in the EU market. This analysis is also linked to the 
realm of production: how these models correlate with catalogue composition (genre, country of origin 
and form) and types of production companies from which the content originates. 

- 

Investment in the European works and the rights market: this part focuses on investment in EU 
markets  for  audiovisual  works.  It  specifically  looks  at  three  parts:  (i)  investments  made  by  public 
service broadcasters in European works, (ii) investments in audiovisual funds by different players via 
levies, (iii) investments made by streaming services. The analysis was conducted for eight countries. 

The findings are presented in the following chapters.  

4.1     The size of the European audiovisual sector and its development 

4.1.1     The structure of the audiovisual market 

Overall, there are 225 089 companies active in EU27, EEA countries and the United Kingdom from across 
all the NACE codes considered in the methodology (see Chapter 2.3   ). The production sector has the highest 
number of active companies, i.e., 179 213 in all of the countries. The highest number of production companies 
was,  by  far,  in  the  United  Kingdom,  followed  by  France  and  the  Netherlands.  Smaller  countries  such  as 
Liechtenstein, Malta and Cyprus have a very low number of production companies.  

The  European  post-production  sector  accounts  for  only  30  753  companies.  However,  the  spread  across 
countries is more balanced than in the production sector. France, the Netherlands, United Kingdom, Spain and 
Slovakia have the highest number of companies.  

The distribution sector has 6,586 companies, with the United Kingdom (1 702), followed by France (1 291), 
Spain (600) and Germany (471) having the highest number of distribution companies. 

Lastly, we also extracted data on the number of companies operating in the  television programming and 
broadcasting  activities  sector.  The  total  number  of  companies  identified  in  EU27,  EEA  and  the  United 
Kingdom  was  8  537,  with  the  highest  number  of  companies  being  located  in  the  United  Kingdom  (2  776), 
followed by Spain (929), Bulgaria (676) and France (469).  

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Figure 3: Number of companies in the audiovisual sector (by NACE code) 

Number of companies in the audiovisual market (2022) 

 60,000
 50,000
 40,000
 30,000
 20,000
 10,000

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J60.2 - Television programming and broadcasting activities

J59.1.3 - Motion picture, video and television programme distribution activities

J59.1.2 - Motion picture, video and television programme post-production activities

J59.1.1 - Motion picture, video and television programme production activities

Source: Authors based on Orbis Europe data 

The table below shows the number of companies per country and NACE code. 

Table 17: Number of active companies in the audiovisual sector (by country) 

J59.1.1 - Motion picture, video 
and television programme 
production activities 

J59.1.2 - Motion picture, 
video and television 
programme post-
production activities 

J59.1.3 - Motion picture, 
video and television 
programme distribution 
activities 

J60.2 - Television 
programming and 
broadcasting activities 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Iceland 

Ireland 

Italy 

Latvia 

Liechtenstein 

Lithuania 

Luxembourg 

Malta 

3 617 

5 334 

1 730 

1 434 

80 

130 

5 014 

1 521 

2 929 

38 284 

5 150 

322 

5 685 

571 

1 013 

6 790 

493 

2 

280 

170 

6 

11 

1 178 

643 

83 

5 

15 

491 

279 

264 

5 701 

1 620 

47 

929 

15 

659 

44 

22 

26 

1 

70 

405 

186 

55 

9 

50 

96 

55 

65 

1 291 

471 

14 

153 

13 

33 

328 

32 

27 

21 

2 

49 

165 

676 

52 

51 

38 

141 

52 

60 

469 

438 

123 

461 

19 

423 

75 

59 

15 

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J59.1.1 - Motion picture, video 
and television programme 
production activities 

J59.1.2 - Motion picture, 
video and television 
programme post-
production activities 

J59.1.3 - Motion picture, 
video and television 
programme distribution 
activities 

J60.2 - Television 
programming and 
broadcasting activities 

Netherlands 

16 336 

Norway 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United 
Kingdom 

6 532 

7 133 

1 571 

4 682 

640 

1 269 

7 469 

10 218 

42 808 

5 168 

604 

1 089 

138 

492 

2 568 

197 

3 183 

1 713 

3 568 

198 

76 

203 

41 

87 

52 

29 

600 

222 

1 702 

103 

91 

380 

95 

360 

40 

129 

929 

268 

2 776 

The overwhelming majority of companies are small in size (96%), while only 3% of companies are medium-
sized  and  only  1%  are  large.147 The  sample  contains  0.1%  of  very  large  companies.  The  majority  of  these 
(35%) are based in the United Kingdom, followed by France (12%) and Germany (10%). Subsidiaries are not 
included separately; rather, global or EU-wide activities of parent companies are included as one company. Of 
the very large companies, 31% fall under motion picture, video and television programme production activities 
(J59.1.1); 5% fall under motion picture, video and television programme post-production activities (J59.1.2); 
7%  fall  under  motion  picture,  video  and  television  programme  distribution  activities  (J59.1.3);  and  47%  fall 
under television programming and broadcasting activities (J60.2). 

Source: Authors based on Orbis Europe 

Figure 4: Number of companies, by size 

Share of companies by size

Very large company
Small company
Medium sized company
Large company

0%

20%

40%

60%

80%

100%

In  2018,  data  from  Eurostat  indicated  a  total  of  108  111  companies  operating  in  the  four  sub-sectors  of 
audiovisual production and dissemination. This suggests that Eurostat data covers only around 48% of the 

147 It should be noted that the definition of business size on Orbis Europe does not match the Eurostat definition. On Orbis Europe, the 
size of companies is based on operating revenue, total assets and employees. On Orbis Europe, companies are considered very large 
when they meet at least one of the following conditions: an operating revenue of at least EUR 100 million, total assets of at least EUR 
200 million, or at least 1,000 employees. Companies are considered large when they meet at least one of the following conditions: an 
operating revenue of at least EUR 10 million, total assets of at least EUR 20 million, or at least 150 employees. Companies are 
considered medium sized when they meet at least one of the following conditions: an operating revenue of at least EUR 1 million, total 
assets of at least EUR 2 million, or at least 15 employees. Companies are considered small when they are not included in the earlier 
categories. On Eurostat, company size only depends on the number of employees. Namely, micro enterprises have less than 10 
employees, small enterprises have between 10-49 employees, medium-sized enterprises have between 50 and 249 employees, and 
large enterprises have 250 or more employees. 

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active companies on Orbis Europe. In 2020, Eurostat indicated 122 696 companies operating in the four sub-
sectors of the audiovisual market, which represent 55% of the active companies on Orbis Europe. 

The number of companies reported on Eurostat in 2018 and 2020 by sub-sector was as follows: 

−  Production: 86 865 (2018); 96 400 (2020) 
−  Post-production: 17 246 (2018); 19 218 (2020) 
−  Distribution: 3 068 (2018); 3 078 (2020) 
−  Programming and broadcasting activities: 4 000 (2018); 4 000 (2020) 

The table below shows the number of companies at country level in 2018 compared to 2020.  

Table 18: Number of companies in the audiovisual sector (2018 and 2020) 

Production 

Post-
production 

Distribution 

European Union - 27 countries (from 2020) 

96 400 

86 865 

TIME  2020 

2018 

2020 
19 218 

2018 
17 246 

2020 
3 078 

2018 
3 068 

Programming 
and 
broadcasting 
activities 
2018 

2020 

4 000 

4 000 

European Union - 28 countries 

106 696 

20 218 

3 752 

5 139 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany  

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

Iceland 

Norway 

United Kingdom 

2 461 

2 462 

582 

543 

2 429 

2 160 

1 991 

591 

394 

291 

206 

533 

360 

210 

168 

134 

61 

116 

47 

62 

55 

79 

131 

99 

66 

6 130 

7 064 

1 224 

1 299 

248 

250 

169 

573 

519 

1 944 

1 819 

1 100 

962 

6 562 

5 974 

125 

338 

266 

758 

100 

297 

258 

580 

19 522 

16 957 

2 186 

2 075 

995 

477 

56 

17 

20 

79 

76 

495 

581 

37 

12 

80 

85 

491 

600 

40 

3 

207 

494 

95 

44 

4 518 

4 354 

1 247 

1 112 

210 

217 

662 

132 

439 

113 

389 

1 333 

1 141 

135 

116 

9 

63 

337 

27 

5 

52 

285 

29 

13 

23 

19 

12 

8 

23 

18 

11 

17 

72 

85 

15 

61 

147 

105 

66 

183 

4 

204 

513 

104 

49 

699 

16 

80 

72 

13 

6 059 

4 961 

1 008 

836 

140 

143 

451 

456 

174 

167 

24 

26 

8 

7 

13 832 

12 022 

4,509 

4,169 

145 

133 

2 146 

1 940 

97 

89 

51 

49 

8 097 

7 079 

1 331 

1 154 

165 

156 

2 548 

2 242 

2 312 

1 946 

1 026 

1 002 

437 

253 

151 

354 

208 

147 

534 

1 165 

568 

996 

2 072 

1 696 

105 

95 

50 

54 

24 

49 

25 

51 

58 

21 

27 

27 

68 

46 

246 

79 

213 

130 

28 

29 

27 

63 

40 

271 

74 

237 

156 

37 

19 

7 492 

7 015 

1 113 

963 

162 

172 

158 

143 

631 

551 

3 085 

2 542 

40 

236 

19 831 

31 

219 

2 972 

8 

44 

4 

48 

684 

39 

31 

32 

25 

1,161 

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Source: Eurostat 

4.1.2     Revenues in the audiovisual market 

Revenues of companies operating in the audiovisual sector are reported based on Orbis Europe data. 148 Of 
the total number of companies in the audiovisual sector, revenue data was available for 24.27% of companies 
from the sample. Companies operating in the audiovisual sector (EEA) generated between 2019 and 2022 
EUR 200 billion, where:  

−  Production: EUR 64 billion  
−  Post-production: EUR 5 billion  
−  Distribution: EUR 20 billion  
−  Programming and broadcasting activities: EUR 111 billion 

Eurostat data from 2018 shows similar results: the combined turnover of companies operating in the production 
and dissemination of audiovisual works amounted to EUR 215 billion. 

The table below provides a breakdown of revenues generated by the audiovisual and media sector by country. 
Some countries are frontrunners across almost all of the audiovisual sub-sectors: 

−  Production: UK (59%), FR (9%), IT (7%), ES (7%) of total revenues 
−  Post-production: UK (26%), FR (32%), ES (9%), DE (9%) of total revenues 
−  Distribution: UK (48%), FR (15%), DE (11%), ES (6%) of total revenues 
−  Programming and broadcasting activities: DE (29%), UK (19%), FR (14%), IT (8%), LT (8%) of total 

revenues 

Table  19:  Revenues  generated  in  the  audiovisual  sector  between  2020  and  2022  (by  country  and 
NACE code) 

J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

€ 150 246 482 
€ 1 214 227 317 
€ 84 185 861 
€ 115 350 377 
€ 119 420 
€ 12 327 741 
€ 206 661 054 
€ 71 712 723 
€ 601 820 875 
€ 5 693 935 577 
€ 2 152 988 878 
€ 301 885 257 
€ 973 337 570 
€ 123 183 479 
€ 1 210 923 206 
€ 4 295 665 798 

0 
€ 9 402 369 
€ 55 611 900 
€ 430 250 
€ 18 441 423 
€ 12 002 
€ 933 196 
€ 13 874 500 
€ 40 380 613 
€ 1 512 060 137 
€ 421 777 727 
€ 16 146 486 
€ 59 952 724 
€ 2 583 871 

€ 284 818 647 

€ 83 707 628 
€ 106 772 436 
€ 195 485 608 
€ 65 937 421 
0 
€ 211 313 687 
€ 48 963 196 
€ 6 929 550 
€ 65 578 883 
€ 2 934 512 959 
€ 2 236 344 198 
€ 156 328 738 
€ 371 862 935 
€ 40 072 161 
€ 321 009 547 
€ 532 688 119 

59 424 693 
1 725 274 970 
254 662 637 
310 685 799 
4 333 508 
552 113 621 
1 365 930 796 
6 108 328 
305 663 544 
15 098 205 811 
32 580 523 493 
653 571 282 
638 698 880 
405 668 

9 284 108 680 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Iceland 
Ireland 
Italy 

148 The Orbis data has been cleaned to exclude duplicates, consider only active companies and include revenue data from 2019 for 
companies where revenues are reported just once. 

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J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

€ 38 419 072 
€ 1 387 194 
€ 85 725 658 
€ 9 819 202 
€ 0 
€ 162 533 509 
€ 795 285 982 
€ 596 182 407 
€ 442 307 702 
€ 579 183 623 
€ 68 395 972 
€168 118 908 
€ 4 181 727 377 
€ 2 193 524 361 
€ 37 658 326 830 

€ 7 676 671 

€ 4 860 904 
€ 7 866 667 
€ 0 
€ 79 581 000 
€ 40 340 634 
€ 74 737 828 
€ 24 730 534 
€ 17 977 990 
€ 183 639 364 
€ 7 172 243 
€ 400 146 583 
€ 143 962 620 
€ 1 233 194 904 

€ 5 009 915 
€ 5 286 696 
0 

83 512 860 
123 632 166 
8 609 711 630 

€ 1 138 786 899 
€ 38 200 722 
€ 228 625 378 
€ 77 935 706 
€ 51 673 891 
€ 15 771 515 
€ 5 531 552 
€ 1 263 381 728 
€ 282 421 403 
€ 9 690 666 545 

1 536 011 448 
1 486 397 980 
2 375 728 327 
2 189 805 610 
339 091 215 
181 358 558 
38 855 318 
6 759 560 812 
3 067 583 878 
21 180 703 496 

€ 64 189 509 412 

€ 4 662 313 787 

€ 20 180 811 777 

110 811 665 008 

Latvia 
Liechtenstein 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Norway 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United 
Kingdom 
Total 

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Annex 7 contains an overview of the revenues generated in the audiovisual sector in 2020, 2021, and 2022 
separately, by country and NACE code. 

Most companies from the Orbis sample are small-sized companies149 (96%), followed by medium (3%), large 
(1%) and very large (under 1%) companies. However, revenue data was reported mostly by large and very 
large  companies,  while  only  22.56%  of  the  very  small  companies  reported  revenue  data  (the  table  below 
provides more details).  

Figure  5:  Shares  of  companies  that  reported  revenue  data  and  the  revenue  generated  (by 
company size) 

Percentage of companies that reported 
revenue, by size

100%

85.55%

81.12%

80%

60%

40%

20%

0%

60.43%

22.56%

Very large

Large

Medium

Small

6020 - Television programming and
broadcasting activities
5913 - Motion picture, video and television
programme distribution activities
5912 - Motion picture, video and television
programme post-production activities

Revenues by company size

160,000,000,000 €

140,000,000,000 €

120,000,000,000 €

100,000,000,000 €

80,000,000,000 €

60,000,000,000 €

40,000,000,000 €

20,000,000,000 €

0 €

Very large
company

Large
company

Medium
sized
company

Small
company

J60.2 - Television programming and broadcasting activities

J59.1.3 - Motion picture, video and television programme
distribution activities

J59.1.2 - Motion picture, video and television programme post-
production activities

J59.1.1 - Motion picture, video and television programme
production activities

Source: Authors based on Orbis Europe data 

4.1.3     Employment in the audiovisual market 

Lastly, the employment data extracted from the Orbis Europe shows that the 761 105 persons were employed 
in the audiovisual media sector between 2019 and 2022 (Eurostat reported nearly 900 000 persons employed 
in 2018).150  

149 According to the Orbis definition 

150 A similar approach to the one used for the revenue data was applied to estimate employment in the audiovisual sector. Since some 
companies reported employment data only for some years, we considered the latest employment data reported between 2019 and 
2022. It should be noted that only 38.12% of the overall Orbis sample reported employment data. 

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The figure below shows the number of employees that reported employment data between 2019 and 2022, by 
company size.  

Figure 6: Shares of companies that reported employment data (by company size) 

Shares of companies that reported employment data (by 
company size)

77.62%

76.55%

67.89%

36.78%

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

Very large

Large

Medium

Small

6020 - Television programming and broadcasting activities

5913 - Motion picture, video and television programme distribution activities

5912 - Motion picture, video and television programme post-production activities

5911 - Motion picture, video and television programme production activities

The table below shows the number of employees per country by NACE codes. Overall, the programming and 
broadcasting activities reported the highest numbers (350 930), followed by production activities (300 310), 
post-production (59 669) and lastly distribution (29 797). 

Table 20: Employment in the audiovisual sector by country and NACE code 

J59.1.1 - Motion picture 
video and television 
programme production 
activities 

J59.1.2 - Motion picture 
video and television 
programme post-
production activities 

J59.1.3 - Motion picture 
video and television 
programme distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Iceland 

4 298 

4 351 

3 476 

937 

- 

46 

4 230 

764 

5 218 

8 978 

22 904 

1 854 

2 978 

407 

16 

346 

1 779 

12 

2 

- 

272 

176 

453 

7 490 

6 820 

165 

333 

14 

131 

355 

3 827 

171 

- 

79 

234 

43 

123 

1 802 

2 834 

237 

533 

85 

407 

5 133 

4 221 

4 020 

- 

4 368 

6 410 

62 

521 

22 301 

171 283 

5 595 

2 881 

7 

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J59.1.1 - Motion picture 
video and television 
programme production 
activities 

J59.1.2 - Motion picture 
video and television 
programme post-
production activities 

J59.1.3 - Motion picture 
video and television 
programme distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

Ireland 

Italy 

Latvia 

Liechtenst
ein 
Lithuania 

Luxembo
urg 
Malta 

Netherlan
ds 
Norway 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United 
Kingdom 
Total 

5 617 

29 465 

703 

9 

527 

8 

- 

14 569 

6 094 

20 147 

3 402 

3 947 

236 

617 

20 436 

8 167 

125 925 

300 310 

13 060 

98 

52 

1 

- 

4 767 

280 

4 007 

289 

200 

722 

87 

3 512 

962 

13 754 

59 669 

717 

1 117 

46 

67 

1 

- 

308 

88 

749 

652 

110 

45 

32 

1 515 

407 

13 489 

29 797 

19 983 

1 194 

1 190 

10 868 

2 663 

5 553 

7 741 

4 631 

3 529 

181 

159 

22 284 

5 769 

37 976 

350 930 

4.2     Business models in the audiovisual sector 

4.2.1     Business models in Video-on-Demand distribution 

Approaches to business models in VoD distribution 

Business models are best understood as combinations of distinct but interrelated parameters spanning the 
production,  packaging/aggregation,  and  distribution/showing 151  of  a  product,  and  a  company’s  choices 
between these options will take different forms according to company ownership, history, size or geographical 
footprint.  Previous  analyses  of  VoD  distribution  have  drawn  on  a  combination  of  indicators  to  characterise 
business  models.  US-based  media  scholar  Eun-A  Park 152 differentiates  services  according  to  ownership, 
vertical  integration  with  content  producers,  platform/multiplatform  compatibility,  service  type  and  revenue 
model. This has led her to identify six different clusters of business models: 

1.  Web  companies  which  act  as  aggregators  of  content  and  primarily  fund  their  services  through 

subscriptions and have multiplatform availability;  

2.  Telecom and pay-TV companies which may be affiliated to broadcasters offering ‘TV everywhere’ on 

predominantly PC/Mac, smartphones and tablets;  

3.  Broadcasters and media companies offering ‘catch-up’ TV funded primarily through advertising on 

PC/Mac, smartphones and tablets;  

151 See: simplified media industries value chain in Doyle, Gillian (2013): Understanding media economics. 2nd ed. London: SAGE. 

152 Park, Eun-A (2019): Prevalence of Business Models in Global OTT Video Services: A Cluster Analysis. In International Journal on 
Media Management 21 (3-4), pp. 177–192. DOI: 10.1080/14241277.2019.1695257. 

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4.  Broadcasters with substantial production of original programming and access to large content 

libraries combining catch-up and broadcast business;  

5.  Telco-companies operating as aggregators of content based on an adverting revenue model;  

6.  Broadcasters relying on rental across all different platforms. 

Park’s analysis of VoD services in 71 countries highlights that there is no single dominant business model in 
the  VoD  market.  She  found  Web  companies  to  be  the  most  prominent  suppliers  of  VoD,  followed  by 
broadcasters and Telecom providers. Furthermore, Park found 44% of services to be vertically integrated with 
content producers, as opposed to services aggregating their content mostly from independent sources.  

In a more simplified fashion and with a focus on the situation in Europe, the European Audiovisual Observatory 
(EAO) has recently classified VoD services according to the business areas where their corporate owners are 
active, distinguishing seven categories of players:  

1.  “Rightsholder – Distributor/Producer: a company exploiting rights and having moved direct-to-

consumer by launching a VoD service. 

2.  Private Equity: a VoD service controlled by investment funds. 
3.  Pure VoD players: a company whose main/sole activity is the operation of a VoD service. 
4.  Film Institute: a public film institute managing its own VoD service. 
5.  Tech: a company also present in sectors other than audiovisual (e.g. Internet services, 

Consumer Electronics, e-commerce, etc.) 

6.  Telecom: a company whose main activity is the operation of telecommunications networks. 
7.  TV: a company whose main activity is broadcasting.”153 

In  their  data  analysis,  the  EAO  also  draws  on  revenue  model  (SVoD  and  TVoD),  catalogue  size  and 
geographical composition as well as the location of corporate owners to  determine how the type of owners 
affects  the  offers  of  VoD  services.  The  EAO  analysis  concludes  that  Tech  players,  Pure  VoD  and 
Telecommunication players offered the largest catalogues, while the services of rightsholders and TV players 
as  well  as  pure  VoD  services  offered  the  largest  share  of  European  film  and  TV  seasons.  Looking  at  the 
countries  of  ownership,  European-owned  catalogues  offered  higher  shares  of  European  film  and  TV  in 
comparison with the  mostly US-owned globally active services.  Another  EAO analysis  of the  VoD services 
available in Europe focuses on the differences in content offered by public and private VoD services, showing 
that public VoD services are mostly free to access and offer a substantially broader range of programmes than 
the film and TV fiction-focused SVoD and TVoD services provided by private players.154 

The  following  analysis  of  VoD  distribution  seeks  to  investigate  how  ownership,  revenue  models  and 
geographical footprint are combined into different business models of VoD services and how widespread these 
models are in the EU’s market. The first step is to refine the distinction of business models by Park and the 
EAO  by  taking  into  account  the  geographical  footprint  of  services  in  Europe.  This  is  because  expanding 
territorial presence affects service content acquisition and catalogue composition practices as they balance 
the potential for growth with the necessity to cater for local market cultural and media systemic specificities.155 
In contrast to the EAO’s analysis of VoD content circulation,156 services with a free-on-demand revenue model 
(FVoD)157 are considered. Though there are overlaps, broadcasters are differentiated from diversified media 
corporations. Tech players are differentiated from VoD tech suppliers to third  parties. The category of Film 
Institutes  is  expanded  to  encompass  film  festivals  and  libraries  that  are  running  VoD  services.  The 
methodology  for  this  analysis  is  described  in  Section  2.3      .  Based  on  the  analysis  of  174  VoD  services 
consolidated from 840 catalogues, nine different business models in VoD distribution are distinguished, which 
are  characterised  using  insights  from  the  Lumiere  VoD  and  Mavise  database  as  well  as  supplementary 

153 Grece, Christian; Jiménez Pumares, Marta (2022): Film and TV content in TVOD and SVOD catalogues. 2021 Edition. EAO. 
Available online at https://rm.coe.int/VoD-catalogues-2021-film-and-tv-content/1680a59d58, checked on 11/1/2022. 

154 See: Schneeberger, Agnes (2023): Audiovisual media services in Europe. 2022 edition. Available online at 
https://rm.coe.int/audiovisual-media-services-in-europe-2022-edition-a-schneeberger/1680a99e7d. 

155 See: Lobato, Ramon (2019): Netflix nations. The geography of digital distribution. New York: New York University Press (Critical 
cultural communication). 

156 Grece, Christian; Jiménez Pumares, Marta (2022): Film and TV content in TVOD and SVOD catalogues. 2021 Edition. EAO. 
Available online at https://rm.coe.int/VoD-catalogues-2021-film-and-tv-content/1680a59d58, checked on 11/1/2022. 

157 FVoD = free to customers at the point of viewing. Funded either through advertising or public funding (licence-fee, tax-funding, etc.) 

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information from academic and industry literature, and interviews with stakeholders in the VoD, broadcasting 
and production industries.158  

A  broad  characterisation  of  the  spread  (Figure  7),  footprint  (Table  21)  and  ownership  of  the  nine  types  of 
services is followed by a more detailed qualitative description of each type and an analysis of trends in the 
presence of recent European content from countries of different production capacity. 

Prevalence of VoD business models and comparison of geographical footprints 

Figure 7: Prevalence of business models compared to numer catalogues among the 174 European 
VoD services in the dataset of 840 catalogues (AT, BE, CZ, DE, DK, EE, ES, FI, FR, HU, IE, IT, LT, LV, NL, PL, 
PT, RO, SE + TR, NO, GB, CH) 

Prevalence of business models compared to number catalogues 
in dataset

broadcaster-born

Telecommunication

Integrated media corporations' services

VoD-born

independent rightsholder

Tech

Services by libraries, archives or film…

7%

10%

9%

19%

17%

17%

26%

13%
13%
13%

21%

6%

1%

5%

9%

N/A

VoD-tech

Cinema

Other

3%
3%
3%

0%

2%

0%

1%

Share of catalogues (without Amazon channels)

Share of services

0%

5%

10% 15% 20% 25% 30%

Table 21: Average geographical footprint in Europe159 by service business model  

Average number of countries in which services are 
active 

Tech companies or platforms expansion 

VoD-born services 

VoD-tech providers 

Independent rightsholders services 

26.8 

15.4 

5.6 

4.5 

158 For details on the methodology of the interview see Section 2.3.  

159 Services with pan-European licenses have been categorized as active in all 41 countries. These are: AL, AM, AT, BA, BE, BG, CH, 
CY, CZ, DE, DK, EE, ES, FI, FR, GB, GE, GR, HR, HU, IE, IS, IT, LI, LT, LV, LU, MA, ME, MK, MT, NL, NO, PL, PT, RO, RS, SE, SK, 
TR, UA 

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Average number of countries in which services are 
active 

Telecommunication providers expansion into VoD 
market 

Integrated media corporations’ services 

Broadcaster-born services 

Services by libraries, archives or film festivals 

Cinema 

3.5 

3.3 

2.0 

1.3 

1.3 

The different geographical footprints of services have been further consolidated into categories of regions, to 
compare  their  spread  and  assess  whether  the  countries  belong  to  common  geo-linguistic  areas.  55%  of 
services in the dataset are only active in one country. 28% can be classified as active across Europe, but on 
varying scales: 29 services are active in 20 or more European countries,160 20 services were active in fewer 
than 20 countries across different regions of Europe. The last group consists of services which are active in 
selected  geo-linguistic  regions.161 Among  these  services,  the  German-speaking  region  accounted  for  nine 
services,  followed  by  Scandinavia  (DK,  SE,  NO)  and  the  Benelux  countries  with  four  services  each.  Other 
regions have fewer services with footprints restricted to their area. 

Figure 8: Geographical footprint of 174 services consolidated from dataset of 840 catalogues 

Prevalence of footprint areas among services

0%

17%

28%

55%

single country

Cross-European

specific geo-linguistic area

N/A

The  ownership  of  the  services  in  the  dataset  was  determined  using  the  Mavise  database,  corporate 
communication and websites as well as industry sources. The majority of services in the dataset are EU27-
owned (103 owned by companies with HQs in EU27, 3 co-owned by EU27 and nonEU country). Of the 64 
non-EU  owned  services  33  are  US-owned,  17  UK-owned  and  14  are  owned  by  corporations  from  other 
countries outside the EU. For 4 services the final ownership could not be conclusively established. 

160 EU27+CH, UK, NO, TR. 

161 Benelux (BE, NL, LU), German speaking region (DE, AT, CH), CZ+SK, French speaking region (FR, BE), English speaking region 
(UK, IE), Scandinavia (DK, SE, NO), Iberia (ES, PT), Baltics (EE, LT, LV). Some services are active across the whole geo-linguistic 
region, some are only active in parts of the region or combine two regions. 

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Figure 9: Region of headquarters of corporate owners of 174 VoD services  derived from dataset of 
840 catalogues 

Corporate ownership of VoD services

2% 2%

37%

59%

EU-owned

non-EU-owned

mixed

N/A

While the majority of unique services are owned by EU-based companies, the non-EU-based companies run 
a larger amount of catalogues in the 23 markets (Figure 10).162 An explanation for this difference between EU 
and  non-EU  players  has  been  offered  by  a  stakeholder  representing  European  VoD  services  as  well  as  a 
stakeholder representing European creatives in the audiovisual sector in the interviews. They explained that 
European services do not have the same possibilities for scaling up their services as US-services, because 
growth in the European market quickly necessitates adaptations to the territories’ language and culture, while 
US-owned services can first grow on the large, homogenous US market before expanding to Europe. 

Figure  10:  Country  of  headquarter  of  corporate  owners  of  VoD  catalogues  from  dataset  of  808 
catalogues (without Amazon channels) 

Country of headquarter of corporate owners of VoD catalogues

EU
29%

mixed
0%

N/A
6%

UK
9%

nonEU
56%

Description of nine VoD service business models 

162 Amazon channels (=32 catalogues) have been taken out of the calculation. 

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Broadcaster-born services: 19% of services in the dataset can be classified as broadcaster-born, because 
they  are  owned  by  a  broadcasting  house  or  group,  whose  main  business  is  the  packaging  of  TV  and  film 
content into TV channels and VoD services. Examples include VoD services of public service broadcasters 
(e.g.,  Raiplay),  services  associated  with  private  broadcasters  (e.g.,  Viaplay)  or  joint  ventures  between 
broadcasting groups (e.g. now defunct Salto – owned by France Television, M6 and TF1). As highlighted in 
Park’s  analysis  of  business  models,  many  of  them  have  their  own  production  capacities  and  can  thus  be 
described as vertically integrated. Broadcaster-born VoD services often bear close association with their linear 
channel and programming brands in their names and the presentation of their content since the majority are 
developments of online catch-up services launched by broadcasters, which since developed through online-
first releases, the curation and presentation of content independent of channel brands163 and the integration 
of different services and brands within their services.164 Among the broadcaster-born services in the dataset, 
the free-VoD revenue model dominates (76%), which can be explained by the strong presence of licence-fee, 
tax-funded  or  ad-supported  public  service  media  in  this  category  of  services,  since  they  are  mostly  free  to 
audiences at the point of service.165 64% of the broadcaster-born services in the dataset are either owned by 
public corporations or have a public service remit. 

Owing to the nation-based governance of public service broadcasters, the majority of the broadcaster-born 
services are also under European ownership and are restricted to single country footprints; only a few extend 
to shared language areas. On average broadcaster-born VoD services are available in two countries. Notable 
European-owned exceptions are SvoD services run by the Viaplay group active in ten countries that go beyond 
the original Scandinavian footprint of the group’s channels and the ITV-owned commercial initiative Britbox, 
currently  expanding  across  different  European  markets.  Though  broadcaster-born  services  are  the  largest 
category in the VoD business models, they only account for 7% of the catalogues.  

Reflecting on the challenges of broadcasters entering the VoD market, during the interviews one stakeholder 
representing  private  broadcasters  pointed  to  high  competition  in  a  crowded  market,  exacerbated  by  high 
production  costs,  legal  and  regulatory  uncertainties,  and  the  contracting  advertising  market  that  is  moving 
towards  a  hybrid  format.  A  stakeholder  representing  European  VoD  services  pointed  to  the  growing  trend 
towards  advertising  as  a  funding  model  for  VoD  services,  which  they  believe  will  contribute  to  a  further 
convergence of broadcast and VoD services. More large players are moving into the AvoD market, for example 
Netflix  which  introduced  advertising  as  a  supplement  to  subscriptions  in  the  US  in  2022, 166 which  creates 
competition  to  the  linear  and  ad-funded  VoD  services  of  broadcasters  with  regard  to  corporate  advertising 
budgets.  

Integrated media corporations services: 17% of services within the dataset can be classified as belonging 
to integrated media corporations. These corporations own subsidiaries across the audiovisual business value 
chain including broadcasters, production houses and rights distributers as well as other media ventures, such 
as book or music publishing houses or advertising services. This category also includes services owned by 
larger  diversified  holding  companies  that  have  a  substantial  involvement  in  media  businesses  (e.g.,  PPF 
Group,  which  owns  Central  European  Media  Enterprises).  These  companies  can  be  described  as  both 
vertically  integrated  (owning  companies  along  the  entire  value  chain)  and  diagonally  integrated  (owning 
companies  in  several  adjacent  business  areas).  Their  integrated  nature  produces  benefits  from  efficiency 
savings, economies of scope as well as control across the value chain,167 for example by holding the rights to 
large catalogues of titles, which reduces operation costs and creates independence from traditional windowing 
in broadcast distribution.168 Diagonal integration of several media enterprises creates opportunities for cross-

163 See: Kelly, J. P. (2021): ‘Recommended for you’: A distant reading of BBC iPlayer. In Critical Studies in Television 16 (3), pp. 264–
285. DOI: 10.1177/17496020211024201. 

164 The Danish SVoD service TV2 Play, for example, offers its subscribers additional content from US-players Hayu or Paramount+ 
which do not find linear distribution on its channels. 

165 According to the EAO’s analysis of revenue models among publicly owned VoD, 79% of these services are free to access. See: 
Schneeberger, Agnes (2023): Audiovisual media services in Europe. 2022 edition. Available online at https://rm.coe.int/audiovisual-
media-services-in-europe-2022-edition-a-schneeberger/1680a99e7d. 

166 Easton, Jonathan: How will Netflix’s ad-supported tier shape the streaming landscape? Available online at 
https://www.digitaltveurope.com/comment/how-will-netflixs-ad-tier-shape-the-streaming-landscape/. 

167 See: Doyle, Gillian (2013): Understanding media economics. 2nd ed. London: SAGE. 

168 See: Lotz, Amanda D. (2017): Portals. A treatise on internet-distributed television. Ann Arbor Mich.: Maize Books an imprint of 
Michigan Publishing. 

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selling169 and cross-promotion. The subscription revenue model dominates in this category of services (53%) 
followed by TvoD (27%). Some VoD brands (e.g., Canal Plus or Joyn) combine the different revenue models, 
giving them more pathways for monetising their content libraries. 

Within this category, 70% of services are owned by corporations headquartered in the EU, such as Vivendi 
(FR), Bertelsmann (DE), MediaForEurope/Mediaset (IT). The non-EU-owned services belong mostly to large 
US-American Media Corporations such as Paramount and Disney. Literature on the large European media 
corporations170 suggests, however, that they have struggled to monetise on synergies of integration and often 
remain restricted to their home territories instead of achieving a global presence like their US counterparts. 
Indeed,  the  VoD  services  owned  by  European  media  corporations  are  mostly  active  in  single  countries  or 
specific  geo-linguistic  regions  that  coincide  with  their  own  or  their  main  subsidiaries’  home  territories  (e.g., 
Germany and Benelux for Bertelsmann, which owns the RTL Group). In contrast to this, the US-owned services 
tend  to  be  active  across  a  number  of  selected  territories  or  close  to  full  European  reach  (e.g.,  Disney+ 
availability in 30 European territories). Together the VoD services of integrated media groups account for 9% 
of catalogues. 

Telecommunication  providers’  expansion  into  VoD  market:  17%  of  services  can  be  classified  as 
telecommunication  providers’  expansion  into  the  VoD  market.  These  VoD  services  are  either  branded 
additions to the larger portfolios of companies offering cable television, mobile communication and/or internet 
access to customers (e.g., VoDafone TV) or acquisitions of broadcasters or VoD players (e.g., Comcast’s 2018 
acquisition  of  Sky  or  TDC’s  2014  acquisition  of  Blockbuster).  This  category  of  players  offers  exclusively 
subscription  or  transaction-based  services.  Despite  the  multinational  activities  of  most  of  these  European 
telecom providers, the footprint of their VoD services is smaller than those of US-owned telco services, active 
across several territories and  mostly  independent of  geo-linguistic areas. On  average, the  VoD services of 
Telco-providers are available across 3.5 countries.  

Telco  providers  have  a  history  as  key  intermediaries  for  broadcasting  through  their  ownership  of  cable 
infrastructure and their role in packaging channels  for the end consumer. Their expansion into VoD can be 
understood  as  a  strategic  response  to  the  potential  decline  in  cable  subscriptions  resulting  from  a  rise  in 
subscription  to  VoD  services  delivered  over  the  internet  (OTT).  Research  by  the  European  Audiovisual 
Observatory has shown that “cord-cutting” is specific to the conditions in different national markets.171 Through 
their VoD services the major European telco providers have expanded this intermediary role to the on-demand 
market, for example by offering bundles of cable+VoD as well as bundles of different VoD services at a cheaper 
price than individual subscriptions for their customers.172 Their ability to create such bundles of communication 
and  audiovisual  services,  as  well  as  their  infrastructural  power  through  their  ownership  of  broadband  and 
content  delivery  networks,  on  which  other  VoD  services  depend,  is  seen  as  providing  telco  players  with  a 
competitive advantage over the newer VoD-born or Tech companies.173  

VoD-born services: 13% of services in the dataset can be classified as VoD-born services. They are owned 
by  companies  whose  main  activity  revolves  around  VoD  and  does  not  include  legacy  media  such  as 
broadcasting  or  other  areas  of  media  production/distribution.  The  geographical  footprint  of  these  services 
extends in most cases (61%) beyond one territory. The footprints among the 52% EU-owned services in this 
category also tend to be larger and less regionally specific than those in the previous categories. The Slovakia-
based service Filmzie, for example, is available in 24 European territories, while Portugal-based Spamflix and 
Spanish  Guide-Doc  hold  Pan-European  licences.  On  average  VoD-born  services  are  available  in  15.4 

169 Bertelsmann-owned VoD service RTL+, for example, integrates podcasts produced by another RTL/Bertelsmann owned production 
company. Krei, Alexander (2022): RTL+ integriert ab nächster Woche Podcasts in seine Musik-App. Available online at 
https://www.dwdl.de/nachrichten/90470/rtl_integriert_ab_naechster_woche_podcasts_in_seine_musikapp/.  

170 See: Bouquillon, Philippe (2017): Vivendi. In Benjamin J. Birkinbine, Rodrigo Gómez, Janet Wasko (Eds.): Global media giants. New 
York: Routledge, pp. 163–180. Meir, Christopher (2021): Corporate consolidation, artistic conservatism and the persistence of 
Hollywood. In Gábor Gergely, Susan Hayward (Eds.): The Routledge companion to European cinema. 1st. London: Routledge 
(Routledge Media and Cultural Studies Companions), pp. 274–284. 

171 See: Ene, Laura (2019): Pay AV services in Europe. The State of Play. Available online at https://rm.coe.int/pay-av-services-in-
europe/168094b6bd.  

172 In 2021, Deutsche Telekom’s Magenta TV, for example, offered bundles with Disney+ and TV Now (now RTL+). Moreover, its VoD 
platform offers access to livestreams of nearly all German linear channels. 

173 See: Evens, Tom; Donders, Karen (2018): Platform power and policy in transforming television markets. Basingstoke, Hampshire: 
Palgrave Macmillan. 

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countries. Because of their relatively large number and wide geographical spread VoD-born services account 
for 26% of catalogues. 

According to the EAO’s analysis of the European VoD market, VoD-born SvoD services such as Netflix offer 
larger catalogues than other types of SvoD services.174 The large catalogues reflect a strategy of appealing to 
a broad customer base, particularly once growth through territorial expansion has been exhausted. 175 While 
this is certainly true on average, the category of VoD-born services also includes a range of brands that cater 
to niches, such as LGBTQ+ film culture (Dekkoo and Revry) and Animé (Animé Digital Network).   

The subscription revenue model accounts for close to half of the services in this category (48%). As explained 
by US-scholar Amanda Lotz,176 the value of content to subscription services lies not in the number of viewers 
they attract, but in their ability to attract continued subscription, which suggests that commissioning choices 
differ from broadcaster-born services with ad-funding legacy. The EAO’s analysis of genre diversity indicates 
that film and TV fiction account for approximately half of SvoD services offerings. In contrast to this, public 
service broadcasters’ free VoD services offer mostly generalist content and only 12% film and TV fiction. 177 
The need for exclusive content that justifies subscription comes at larger upfront costs for the VoD services 
and increases competition  for talent and content. This situation  has resulted  in  the  expansion of VoD-born 
SvoD services into content production, for example, Netflix has established its first European production hub 
in Spain.178 A stakeholder from the European production industry has raised the issue that it is easier for US-
based VoD services to secure talent (writers, directors and actors) than their European counterparts because 
of the financial power.  

Alongside the dominant SvoD revenue model, the advertising-funded model is prominent among VoD-born 
services  (30%).  Several  large  US-players  (Netflix,  HBO  and  Disney)  have  begun  to  introduce  advertising 
funding on their domestic market to supplement subscription-funding, but European audiences are expected 
to  be  less  tolerant  towards  ads  than  US  customers,179 which  may  dampen  the  roll-out  of  hybrid  models  by 
VoD-born services. Genre-specific or niche services, however, are expected to maintain subscription funding 
because they lack the scale to successfully implement advertising funding. 180 

Independent  rightsholders  services:  13%  of  services  in  the  dataset  are  owned  or  run  by  production 
companies or distributers of audiovisual rights that are fully independent, i.e., not owned by a major media 
corporation or broadcaster. Subscription and transactional revenue models dominate. The majority of services 
in this category are EU-owned (75%). Their VoD services can be exclusive outlets for their content enabling 
them to create a direct relation with the end customer instead of depending on aggregators like channels or 
other VoD services. This is, for example, the case for British documentary distributer Dogwoof, which runs its 
own VoD service. This presents a form of downstream expansion, but their own VoD services are more of an 
additional  revenue  stream  than  a  permanent  substitute  for  distribution  via  other  channels,  e.g.,  cinema, 
broadcast via other VoDs.181  

174 Grece, Christian; Jiménez Pumares, Marta (2022): Film and TV content in TVOD and SVOD catalogues. 2021 Edition. EAO. 
Available online at https://rm.coe.int/VoD-catalogues-2021-film-and-tv-content/1680a59d58, checked on 11/1/2022.  

175 After completing its global expansion in 2016, Netflix has increased its efforts to dig deeper into markets by offering not only fictional 
series but also reality and entertainment productions. See: Elmes, J. (2022). Netflix plots to expand unscripted universe. Retrieved from 
https://www.broadcastnow.co.uk/netflix/netflix-plots-to-expand-unscripted-
universe/5170125.article?utm_medium=email&utm_campaign=Daily%20Daily%20News&utm_content=Daily%20Daily%20News+CID_4
bf0a326f23ae51594c7ee058f4af6c3&utm_source=Newsletter&utm_term=Netflix%20plots%20to%20expand%20unscripted%20universe 

176 Lotz, Amanda D. (2017): Portals. A treatise on internet-distributed television. Ann Arbor Mich.: Maize Books an imprint of Michigan 
Publishing. 

177 Schneeberger, Agnes (2023): Audiovisual media services in Europe. 2022 edition. Available online at https://rm.coe.int/audiovisual-
media-services-in-europe-2022-edition-a-schneeberger/1680a99e7d. 

178 See: Afilipoaie, Adelaida; Iordache, Catalina; Raats, Tim (2021): The ‘Netflix Original’ and what it means for the production of 
European television content. In Critical Studies in Television 16 (3), pp. 304–325.  

179 Easton, Jonathan: How will Netflix’s ad-supported tier shape the streaming landscape? Available online at 
https://www.digitaltveurope.com/comment/how-will-netflixs-ad-tier-shape-the-streaming-landscape/. 

180 Easton, Jonathan: How will Netflix’s ad-supported tier shape the streaming landscape? Available online at 
https://www.digitaltveurope.com/comment/how-will-netflixs-ad-tier-shape-the-streaming-landscape/. 

181 Corvin, Anne-Marie (2021): Doc Sales Agents Switch from Acquisition to Financing and Co-Pros as Feature Length Doc Slates Fill 
Up. Available online at https://variety.com/2021/film/festivals/doc-sales-agents-switch-from-acquisition-to-financing-and-co-pros-as-
feature-length-doc-slates-fill-up-1235015842/. 

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The  Independent  rightsholders  services  may  brand  themselves  as  alternative  spaces  to  big  US-based 
services,  as  in  the  case  of  European  service  Sooner. 182  The  services  can  also  present  themselves  as 
alternatives to other rights owners creating also a producer-faced business, e.g., by offering revenue sharing 
(e.g.,  Pantaflix).  On  average,  the  independent  rightsholders  services  were  active  in  4.5  countries  and 
accounted for 13% of catalogues. Of the 23 services in this category only three are active across the whole of 
Europe and only one of these services is EU-owned: DaFilms from Czechia.  

Expansions  of  Tech  companies  or  services  into  the  VoD  market:  6%  of  services  can  be  classified  as 
expansions of technology companies into the VoD market. In contrast to VoD-born services, Tech companies 
or services are active across a range of digital business areas, such as hardware, e-tail, online advertising, 
search engine  provision  or the rental of servers. This means they are owned by companies predominantly 
active in hard- or software production (Apple, Microsoft and Sony) or online businesses (Alphabet, Rakuten 
and Amazon). Despite this small share in European services, this category includes many of the big players 
in VoD, namely Amazon Prime Video, Apple TV+ and YouTube’s SVoD and TVoD services. Together Tech 
services  account  for  21%  of  catalogues.  The  Tech  companies’  VoD  services  are  monetised  by  large 
catalogues,183 a mix of SVoD and TVoD revenue models and a large footprint that spans across Europe. With 
the exception of Stream, owned by the Czech online portal Seznam, services in this category are exclusively 
non-EU owned.  

According to Nick Srnicek184, online giants such as Amazon or Google have a tendency to expand in this way 
into other business areas in order to boost their customer base and broaden their collection of user data, which 
can either be used for refining their own services or be108onetizind and sold to third parties. Furthermore, 
Apple  TV+  and  Amazon  Prime  Video  have  demonstrated  how  VoD  services  can  be  tied  to  their  core 
businesses  of  device  sales  and  online  retail  respectively,  as  the  VoD  subscription  is  added  to  customer 
purchases  of  Apple  devices  or  subscriptions  to  the  Amazon  Prime  delivery  service.  Hence,  the  business 
models of these companies do not revolve solely  around  generating  profits from the  VoD service, but  also 
involve  adding  value  to  their  original  services/products  and/or  helping  them  expand  their  user-data-driven 
businesses.  

Purchases of production studios and content libraries, for example, Amazon’s 2022 takeover of MGM185, show 
how Tech corporations are also striving to develop efficiency savings, economies of scope and levels of control 
(particularly concerning the availability of rights) afforded by vertical integration. Beyond running their own VoD 
services, the big Tech giants play a role as key intermediaries for distributing other VoD services, whether 
through Amazon Channels,186 the app-stores of Apple and Google or TV operating systems such as Amazon’s 
Fire TV. Therefore, their role as gatekeepers in the VoD industry should be considered part of their business 
model.  In  this  gatekeeping  function  they  can  be  seen  as  new  competitors  to  legacy  telecommunications 
players. 

Services by libraries, archives or film festivals: 5% of services in the dataset can be described as being 
run by cultural institutions such as libraries, archives or film festivals to showcase their content and make it 
available online. Loaning audiovisual content online via public libraries is possible in the Nordics. Film Festivals 
such as the Rotterdam International Film Festival run their own streaming services to extend their event across 
time and space. These services are only available in the territories where the cultural institutions are active. 
As their funding mostly depends on public support and/or sponsorship, their business model is best understood 
as an extension of this use of public or private funds to further cultural goals such as the education of citizens 
or the promotion of film culture. 

VoD Tech providers to third parties: 3% of services in the dataset can be described as providers of VoD 
technologies to third parties. While they also run VoD services of their own, a major part of their business is 
supplying third parties, such as cinemas or independent producers or individual filmmakers with technological 

182 Niemeier, Timo (2020): Neue europäische Streaming-Plattform Sooner ist gestartet. Available online at 
https://www.dwdl.de/nachrichten/78710/neue_europaeische_streamingplattform_sooner_ist_gestartet/, updated on 7/29/2020.  

183 See: Grece, Christian; Jiménez Pumares, Marta (2022): Film and TV content in TVOD and SVOD catalogues. 2021 Edition. EAO. 
Available online at https://rm.coe.int/VoD-catalogues-2021-film-and-tv-content/1680a59d58, checked on 11/1/2022. 

184 Srnicek, Nick (2017): Platform capitalism. Cambridge, UK, Malden, MA: Polity (Theory redux). 

185 Maas, Jennifer (2022): Amazon Closes $8.5 Billion Acquisition of MGM. Available online at https://variety.com/2022/tv/news/amazon-
mgm-merger-close-1235207852/, updated on 3/17/2022. 

186 Among the 23 Amazon Channels in the dataset of this analysis are VoD offers by broadcasters like ITV and ZDF, major media 
corporations like Discovery and VoD-born players like MUBI. 

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solutions  for  setting  up  streaming  services  or 109onetizingg  their  content  through  streaming.  The  French 
company VoD Factory, for example, owns a streaming service for horror films, but as its main business it offers 
technological tools for creating VoD services, as well as distribution and marketing support for brands. The 
Tech providers also offer producers new ways of109onetizingg their content, for example UK-based service 
Paus offering an NFT-based solution for exploiting films. The main business of these services is thus focused 
on content creators or other parties exploiting audiovisual rights, not VoD audiences. 

Online cinema: this small (2%) category contains streaming services owned by cinema chains or run in co-
operation with cinemas. The former, exemplified by Curzon Home Cinema (GB, IE), is based on a catalogue 
of films with a promotional focus on recent releases that have just left the cinemas. This kind of online cinema 
can be seen as a way of profiting from the on-demand release window just after cinema screening. The second 
type is an expansion of the cinema release for films. An example is the Dutch service Picl which launched in 
2015, based on cooperation between independent cinemas and distributors, where a share of the streaming 
proceeds  goes  back  to  the  participating  cinemas.  The  revenue  model  of  these  services  is  exclusively 
transaction-based, and they are restricted to the countries in which the cinemas/cinema chains are active.  

Other:  This category (1%) contains  those services that could not  be  assimilated into  one of the  preceding 
categories,  for  example  because  they  are  owned  by  media  companies  that  are  neither  broadcasters  nor 
independent holders of audiovisual rights nor integrated into bigger media companies (e.g., the Finnish book 
retailer Booky).   

N/A: This category (3%) refers to players that could not be classified because they have either ceased to exist 
or because of a lack of information about their ownership or footprint. 

Comparison of the availability of titles from European countries according to VoD service type 

The EAO offers a discussion of catalogue sizes and the levels of European vs. non-EU content across different 
types of service.187 This analysis of the Lumiere VoD data described in the Methodology Section 2.3   focuses 
on the availability of EU27+UK content from 2020 and 2021 first-produced in European countries with different 
sizes and production capacities on the different types of VoD services (Figure 11).188 The aim is to assess how 
different  business  models  can  affect  the  profile  of  their  content  and  thereby  their  positions  as  buyers  from 
European content producers, who are the focus of the next step in the analysis. 

187 Grece, Christian; Jiménez Pumares, Marta (2022): Film and TV content in TVOD and SVOD catalogues. 2021 Edition. EAO. 
Available online at https://rm.coe.int/VoD-catalogues-2021-film-and-tv-content/1680a59d58, checked on 11/1/2022. 

188 The services operated by libraries, archives or film festivals as well as those by cinema operators and the “other” category have been 
taken out of the calculation because of the low number of catalogues and the fact that catalogues of these types can only be found in a 
few countries which is likely to affect what content they offer. 

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Figure 11: Share of content from first-producing countries with different production capacities within 
the 2020/21 EU27+UK content available on the different types of service 

The catalogues of VoD-born services and the services of independent rightsholders in the dataset have an 
above 50% share of content first-produced in large high production capacity countries (DE, ES, FR, IT), but 
less content from the UK. In contrast to this, the tech services and those run by telecom corporations have 
high shares of UK first-produced content (46%). The preference for English-speaking content among these 
providers can be explained by their tendency to have large footprints that go beyond Europe.  

Broadcaster-born  services  have  the  highest  share  (35%)  of  content  from  the  small  markets  with  high 
production capacity (AT, BE, DK, FI, IE, NL, SE), which even surpasses the share of the content from large 
high-capacity markets (26%). This tendency can be explained by the high prevalence of VoD services run by 
public  service  broadcasters  in  national  markets  whose  remits  are  focused  on  the  commissioning  and 
production of content in the national language and targeting the national community.  

The lowest share of UK content (12%) is found in the services of independent rightsholders, which can be 
explained by the fact that only three of the 23 services in this category are active across all European markets. 
The majority are limited to single markets or geo-linguistic territories which often coincide with those of the 
independent rights owner running the service. For example: on the service AeroVoD, which is active in Czechia 
and  Slovakia,  and  was  established  by  the  Czech  independent  distributor  Aerofilms,189 64%  of  the  2020/21 
European productions have Czech and/or Slovakian co-producers.   

The  high  share  of  Austrian  content  in  the  category  “VoD  tech”  can  be  explained  by  the  catalogue  of  the 
Austrian-based service KinoVoD Club that offers Austrian cinemas the opportunity to provide Austrian films as 
pay-per-view streams. 

Content  first  produced  in  the  low  production  capacity  countries  for  which  catalogues  were  present  in  the 
dataset,190 on average accounts for 5.6% of the EU27+UK-productions from 2020/21 in the catalogues of the 
different types of service. If the low production capacity countries for which no catalogues were available are 
added, this share rises to 6.6%. The services from independent rightsholders have a larger than average share 
of low-capacity country productions, possibly because three of these services are based in Czechia (AeroVoD, 
DaFilms, KoukeYTe).  

The VoD-born services include a high share of Polish content (5.5%) which may be due to the fact that Poland 
is the largest of the low production capacity countries and therefore has not only a comparatively higher output 

189 Aerofilms was taken over by KVIFF Distribution in December 2021, which is a subsidiary of Karlovy Vary International Film Festival. 

190 CZ, PL, PT, RO, EE, HU, LV, LT. 

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of content,191 but also a larger potential customer base who are also more accustomed to domestic content 
than those in small countries with very low production levels. In contrast to this, the VoD services run by Tech 
companies have a below average share of LCC country content in the EU27+UK productions from 2020/21 in 
their catalogues (2.8%). 

Figure 12: Share of content from first-producing countries with different production capacities within 
the 2020/21 EU27+UK content according to the ownership of services 

An analysis of the differences between the different types of service and their final ownership (Figure 12)192 
shows that EU-owned VoD services have the lowest reliance on British content produced 2020/21 and have 
the highest share of content from both the large and small EU countries with high production capacity. UK-
owned services had the highest share of productions from low-capacity countries. This is probably due to the 
23 catalogues of UK-owned VoD-born service MUBI, in which LCC-first produced content accounts for 16.2% 
of  the  EU27+UK  productions  from  2020/21.  Non-EU-owned  services  offer  less  content  from  low-capacity 
countries and rely more heavily on British and Spanish content than EU-owned services, which is not surprising 
considering that the non-EU-owned services often have a global footprint and therefore content in English and 
Spanish allows them to reach large parts of the world population.  

It should be noted that this analysis of catalogue presence of content from countries with different production 
capacities does not reveal anything about the prominence and discoverability of this content on the individual 
types of service, particularly when the high shares of non-EU content on particular types of service (VoD-born, 
Tech) are considered. 

4.2.2     Business models in film and television production and their intersection with VoD business 
models  

Approaches to business models in audiovisual production 

The  audiovisual  (AV)  production  landscape  in  Europe  is  large  and  diverse.  Looking  only  at  TV  fiction 
production,  the  European  Audiovisual  Observatory  estimates  that  nearly  1,200  production  companies  or 
groups (in EU27+UK) produced a title in 2020. Yet, only 7% of these companies produced at least one title per 

191 Poland immediately follows the big European markets DE, GB, FR and ES in number of TV fiction series produced between 2015 
and 2020. Fontaine, Gilles (2022): Audiovisual fiction production in Europe. 2020 Figures. Available online at 
https://rm.coe.int/audiovisual-fiction-production-in-europe-2020-figures/1680a5d715, p. 19. 

192 Services with mixed ownership have been taken out of the calculation since only three services are co-owned by EU/non-EU players. 

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year  since  2015. 193  Therefore,  even  among  the  roughly  179,000  active  production  companies  in  the 
EU27+EAA+UK (see section 4.1   ), only a small share will have actively (co-)produced a title in 2020/21.  

Distinguishing business models in production, ownership structure and vertical integration provides important 
information about a producer’s activities and position in the market. Doyle et al. ‘s 2021 study of the British 
television production sector distinguishes between independent, ‘super indie’ conglomerates and partially/fully 
vertically integrated companies as well as between different company sizes, content profiles and country of 
corporate  ownership.  Their  study  finds  that  the  expansion  of  digital  distribution  services  has  resulted  in  an 
increased drive for scale and integration in TV production, which 112aterializes in acquisitions of producers by 
transnational media corporations and TV conglomerates and a consolidation of producers into ‘super-indies’. 
They argue that greater scale, transnational activity and vertical integration present advantages and growth 
opportunities for producers.194 In the EU, we also find a number of vertically integrated media groups195 and 
large production houses therein,196 as well as partially integrated ‘super-indies’ outside of these large media 
groups.197 However, the audiovisual sector is largely fragmented, which means that many different and often 
small companies will be involved from creation to the distribution of a finished product to audiences, forming 
individual networks of collaboration, co-production and dependency.  

This  section  determines  and  examines  prevalent  business  models  in  the  production  of  film  and 
televisual content with a focus on company size, the ownership and integration of companies along 
the value chain and assesses how they correlate with different VoD business models and distribution 
patterns  across  catalogues  and  countries.  Following  Doyle  et  al.’s  2021  study  of  the  British  production 
sector,198 business models in production are assessed based on company size, ownership, vertical integration 
along the value chain, types of products and patterns of product circulation. Description and explanations of 
the dataset, indicators and data sources used can be found in the Methodology Section 2.3   .  

The following limitations apply to the analysis of business models in production. As shown in section 4.1    the 
European production landscape is much larger than the number of companies producing a title in a given year 
and succeeding in distributing it on video-on-demand. European production companies that have produced 
content in 2020/21, which has not (yet) been distributed on VoD, are omitted, because this study is interested 
in  the  intersection  between  production  and  VoD  distribution  business  models.  The  choice  of  focusing  on 
2020/21 titles that have received VoD distribution has the benefit of catching production companies actively 
producing in the reference period and it allows for the combination of production and distribution data.  

Further limitations are introduced by the availability of data: the Lumiere VoD data used as the basis for this 
study does not contain catalogues for BG, CY, GR, HR, LU, MT, SI and SK, which means that there are only 
few titles from these countries in the dataset. This limits the conclusions that can be drawn about the situation 
in these mainly low production capacity markets. Because only 1,897 producing companies could be retrieved 
through  the  combination  of  Lumiere  VoD  and  TMDB  and  only  78%  of  these  could  be  enriched  with  Orbis 
information  on  company  size,199 this  study  can  only  elucidate  a  sample  of  European  film  and  TV  content 
producers  active  in  2020/21.  It  is  likely  that  particularly  smaller  companies, 200  those  producing  non-
fiction/entertainment  titles  and  those  in  low-capacity  markets  are  underrepresented  in  the  sample. 
Nonetheless, the data reveals some indicative trends regarding the activity levels of companies according to 

193 Fontaine, Gilles (2022): Audiovisual fiction production in Europe. 2020 Figures. Available online at https://rm.coe.int/audiovisual-
fiction-production-in-europe-2020-figures/1680a5d715, p.7. 

194 Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the 
digital challenge. Basingstoke: Palgrave Macmillan, p. 194-195. 

195 E.g. Bertelsmann (DE), Vivendi (FR), Mediaset (IT), Egmont (DK), Bonnier (SE).  

196 E.g. Fremantle (Bertelsmann, DE), Studiocanal (Vivendi, FR), Taodue (MedieForEurope/Mediaset, IT), Nordisk Film (Egmont, DK), 
SF Studios (Bonnier, SE). 

197 E.g. Banijay (FR), Asacha Media (FR), Constantin Film (DE). 

198 Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the 
digital challenge. Basingstoke: Palgrave Macmillan.  

199 Orbis assesses company size “based on operating revenue, total assets and employees” Orbis assesses company size “based on 
operating revenue, total assets and employees” (Orbis Data Dictionary). 

200 Orbis reports 225,388 small (95.9%), 7,769 medium (3.3%), 1,467 large (0.6%) and 353 very large (0.2%) companies in the 
audiovisual sector in the EEA. 

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size  and  the  correlations  of  company  size  and  the  distribution  of  their  works  across  VoD  catalogues  and 
countries.  

It is not possible on the basis of the sample of 143 companies for which a detailed analysis of ownership and 
integration  has  been carried out (see  Methodology Section  2.3    ) to  make  affirmations about the absolute 
prevalence of these types of business models in Europe or the different countries, because only producers 
with a high output201 in the reference period were considered. Moreover, important large producers as well as 
further productions by the top producers found may have been omitted because they were not detected in the 
matching between the Lumiere VoD catalogue data and the TMDB database. Because of the limitations of the 
data on producers, the typology of the seven production business models offers a qualitative differentiation of 
the activity of dominant producers in the European market, rather than an assessment of the spread of these 
models across Europe. This is also why it was not possible to make a comparison of the presence of these 
business models in different countries. 

In  the  following  an  overview  is  provided  of  the  activity  levels  and  the  spread  of  company  sizes  among  the 
producers with TV/film titles from 2020/21 that could be identified by matching the Lumiere VoD, TMDB and 
Orbis  data.  Thereafter  circulation  patterns  of  this  content  are  analysed  with  a  focus  on  a  comparison  of 
countries to determine the existence of sales opportunities for first producers located in the country as well as 
opportunities for companies of different sizes to sell to VoDs with different business models. This quantitative 
approach to the situation in the European production market is followed by a qualitative description of seven 
business models prevalent among the European producers with a high content output from 2020/21 circulating 
on VoD.  

Activity and size of producers 

Figure 13 shows the volume of VoD-circulating film titles/TV series (co-)produced by companies in EU27+UK 
in 2020/21, which could be identified from the Lumiere VoD catalogue data using TMDB. Nearly two-thirds of 
companies (co-)produced only one title in 2020/2021. 24.2% of companies (co-)produced at least one title in 
both 2020 and 2021. Focusing only on first productions, just under half of the companies (48%) in the TMDB 
dataset were first producers of at least one film or TV season in 2020/21.  

Figure 13: Comparison of volume of first and co-productions of film and TV seasons in 2020 and 2021 
with VoD distribution based on data from TMDB (total 1,897) 

Comparison of companies' volume of first and co-productions of 
film and TV seasons in 2020 and 2021 with VoD distribution based 
on data from TMDB (total 1,897)

52%

34%

65%

11%

27%

0 productions

0%

1 production

2 to 4

5 to 9

10 to 19

20 to 29

30+ productions

2%

5%

1%

2%

0%
1%
0%
1%

0%

10%

20%

30%

40%

50%

60%

70%

Share of companies with number of first productions

Share of companies with number of co-productions

201 ≥ 5 first or film or TV co-productions identified in the reference period. 

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The overall comparison of company sizes (Figure 14) shows that small companies account for more than half 
of the producers that could be matched to (co)productions from 2020/21 (total 1 477 companies). Together, 
the  large  and  very  large  companies  account  for  15%  of  companies  in  the  dataset,  while  the  majority  of 
companies  can  be  classified  as  small.  Rather  than  giving  us  information  about  the  absolute  prevalence  of 
company sizes in the European market, these numbers show which sizes of companies have their content 
circulating on VoD. 

Figure 14: Comparison of company sizes based on data from Orbis (total 1 477 companies) 

4%

11%

32%

53%

S

M

L

XL

The sample of 789 small producers accounted for 36.3% of titles (co-)produced in 2020 and 2021, which is 
nearly  equivalent  to  the  output  of  the  large  plus  very  large  producers.  On  average  small  producers  (co-
)produced  1.5  titles  in  the  reference  period,  compared  with  1.8  by  medium-sized  companies,  3.7  by  large 
companies and 9.2 by very large companies.  

Figure 15: Share of titles first produced by company sizes (base 909 companies which acted as first 
producers) 

XL
27%

L
20%

S
30%

M
23%

Looking  at  the  distribution  of  company  sizes  among  first  producers  (Figure  15),  we  see  that  very  large 
producers accounted for over a quarter of the 1 459 film and TV titles from 2020/21 for which size information 
on first producers was available.   

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Figure  16:  Prevalence  of  different  company  sizes  according  to  production  capacity  (base  1,477 
companies) 

4.2%
11.0%

34.8%

50.0%

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

4.2%
9.5%

25.8%

6.5%
8.3%

41.7%

1.7%

1.7%

36.2%

4.1%

14.1%

21.8%

60.4%

60.3%

60.0%

43.5%

large high
capacity

small high
capacity

LCC A

LCC B*

GB

S M L

XL

Comparing the distribution of company sizes across countries (Figure 16) gives an indication of what size of 
companies are engaged in productions successfully placed on VoD. The figure above reveals that the UK has 
the highest share of large and very large production companies combined, followed by the large high-capacity 
markets.  Since  we  can  expect  more  large  and  very  large  companies  in  big  high-producing  countries,  this 
tendency is not surprising. However, the small high-capacity countries manage to have a higher share of small 
companies whose content achieves VoD distribution, similar to the level of the UK where it seems to be ‘the 
middle’  that  is  more  squeezed  than  in  other  markets.  LCC  A  countries  have  the  lowest  number  of  small 
companies whose content circulates on VoD, which suggests that it is rather the medium to large companies 
in these countries that succeed in placing their content to VoD. It should be noted that the very large companies 
in the smaller markets (e.g. DK, PT, SK) are almost exclusively broadcasters,202 while very large production 
companies  (either  independent  or  integrated  into  larger  media  corporations)  are  mostly  found  in  larger 
countries  (e.g.  Constantin  Film  in  DE,  Warner  Brothers  Entertainment  Spain  in  ES  and  Pathé  in  FR).The 
available  data  for  LCC  B  countries  is  limited  to  53  companies,  due  to  the  fact  that  for  many  of  them  no 
catalogues  could  be  retrieved  from  the  Lumiere  VoD  database,  and  also  due  to  the  limited  availability  of 
company data from Orbis. The available data suggests that the countries have very low levels of large and 
very large companies engaged in VoD distribution of their content, leaving it to the small and medium-sized 
companies to capitalise on their content.203 

Circulation of content by producers of different sizes, countries of origin and types 

Looking at the circulation of titles according to the different size of their first producers, we see that the content 
of larger production companies tends to be present in more catalogues and countries with the exception of 
extra-large companies.  

202 The only exception is the children’s TV producer (and owner of amusement parks) Studio 100 in Belgium which is classified as a very 
large company. 

203 High-capacity large countries: DE, FR, ES, IT. High-capacity small countries: AT, BE, DK, FI, IE, NL, SE. LCC A: CZ, EE, PL, PT, 
RO, GR, HR. LCC B: HU, LT, LV, CY, LU, MT, SI, SK, BG. *Note: The data on the LCC B markets is based on just 58 companies. 

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Table 22: Average circulation of titles by size of first producer (base 909 producers, i.e., those with first 
productions in 2020/21) 

Company size 

Average number of catalogues in 
which their first productions are 
present 

Average number of countries204 in 
which their first productions are 
present 

XL 

L 

M 

S 

N/A 

16.6 

17.8 

13.7 

11.9 

13.5 

5.0 

7.2 

6.8 

6.4 

5.2 

Looking at the geographical distribution of content from first producers of different sizes (Figure 17), very large 
companies  have  a higher  share of  productions that remain within one territory.  A likely  explanation for  this 
trend is that 35% of the very large companies in the dataset are public service broadcasters. Most PSBs have 
a remit that focuses their attention on productions for the domestic market. If the public service broadcasters 
are  taken  out  of  the  distribution  data  for  extra-large  first  producing  companies,  the  average  of  countries  in 
which their first produced content circulates rises to 8.5.  

Large companies in the dataset have the highest share of titles that achieve cross-European distribution in 17 
or  more  countries.  The  medium-sized  companies  have  the  highest  share  of  productions  that  achieve 
distribution in selected countries (2-6). The distribution patterns of content first produced by small companies 
are  not  very  different  from  the  larger  companies,  indicating  that  the  content  of  small  companies  is  not 
necessarily disadvantaged when it comes to geographical distribution. Still their content is present in markedly 
fewer catalogues than that of large or very large producers. This analysis does not reveal the conditions under 
which content is being distributed.   

204 From list of 23 countries whose catalogues could be retrieved from the Lumiere VoD database: AT, BE, CH, CZ, DE, DK, EE, ES, 
FI,FR, GB, HU, IE, IT, LT, LV, NL, NO, PL, PT, RO, SE, TR. 

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Figure 17: Comparison of circulation of titles first produced by company sizes (basis productions 
by the 909 companies, which acted as first-producers) 

1 country

2-6 countries

7-11 countries

12-16 countries

17+ countries

X L

L

M

S

47%

32%

7%

3%

11%

32%

34%

11%

5%

19%

26%

43%

9%

6%

16%

33%

35%

10%

6%

14%

Figure 18: Circulation pattern of content from producers of different size on different VoD service types 

XL

L

M

S

0%

20%

40%

60%

80%

100%

broadcaster-born

Integrated media corporations'
services
Telecommunication

independent rightsholder

Services by libraries, archives or
film festivals
Cinema

VoD-tech

N/A

VoD-born

Tech

The distribution of content from first producers of different sizes on different types of VoD services (Figure 18) 
shows  a  relatively  similar  pattern  across  company  sizes,  which  indicates  that  there  are  no  pronounced 
preferences  for  buying  from  certain  sizes  and,  by  extension,  types  of  producers  among  the  different  VoD 
distributers’ business models. VoD-born and Tech VoD services provide the most ‘circulation opportunities’ for 
producers of all sizes. Their catalogues account, on average, for 60% of producer content’s circulation. This 
can be explained by their tendency towards large geographical footprints and large catalogues (see section 
4.2.1      ).  It  should  be  noted  that  this  analysis  of  catalogue  presence  does  not  say  anything  about  the 
prominence and discoverability of content from companies of different sizes in the catalogues of the different 
VoD business models. 

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Figure 19 ranks first producers’ countries according to the extent of their content’s circulation in the 23 markets 
included in the Lumiere VoD data.205 

Figure 19: Distribution pattern of first-produced content by country of producer (base 1,832 titles) 

Geographical availability of titles by first producer's country

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

10

9

8

7

6

5

4

3

2

1

0

CZ

FI

PT

NL

PL

IT

DE

FR

SE

ES

AT

BE

DK

GB

IE

1 country

12-16 countries

2-6 countries

17+ countries

7-11 countries

Average number of countries

Comparing  the  geographical  circulation  of  content  according  to  first  producer’s  country,  we  see  that  first 
producers in the English-speaking countries Ireland and Great Britain have a clear advantage when it comes 
to a wide geographical circulation of their recent productions, averaging 8.3 countries for the UK and 8.9 for 
Ireland.  First  producers  in  the  small  countries  Denmark,  Belgium  and  Austria  also  have  an  above  average 
geographical circulation of their 2020/21 content. The wide circulation of content from Spanish first producers 
could  be  due  to  the  prevalence  of  the  Spanish  language  across  the  globe,  which  makes  Spanish  content 
attractive  to  Tech  and  VoD-born  players  with  a  reach  beyond  the  European  markets.  The  content  of  first 
producers  in  the  big  western  European  markets  that  are  Italy,  Germany  and  France,  as  well  as  in  smaller 
Sweden, is distributed on average in between 5 and 6 countries.  

In contrast to this, first producers in Czechia, Finland, Portugal, the  Netherlands and  Poland  have a  below 
average geographical circulation of their content. For Germany and France – as well as for the Netherlands 
and  Austria  –  the  higher  share  of  distribution  in  2-6  countries  indicates  the  distribution  of  their  content  in 
countries with the same language. For the Nordic countries, the high share of distribution in 2-6 markets can, 
in  part,  be  explained  through  institutionalised  co-funding  and  co-production  in  the  region  (e.g.,  through  the 
PSM network Nordvision), which secures distribution via the services of the co-producing partners. 

Looking  at  the  number  of  catalogues  in  which  the  content  of  first  producers  circulates  combined  with 
information on the location of these catalogues, we see that producers in some countries (CZ, FI, IT, NL) are 
more  dependent  on  domestic  VoD  services  than  those  with  a  larger  share  of  productions  in  non-domestic 
catalogues (AT, BE, DK, IE, PT, SE, GB). These numbers give an indication of sales opportunities, which are 
not only due to the content’s market attractiveness, but also the number of catalogues in domestic and potential 
sales  markets  (see  in  section  2.3      ),  country-specific  traditions  for  co-production,  financing  and  rights 

205 BG, CY, EE, GR, HR, HU, LT, LU, LV, MT, RO, SI, SK have been taken out of this calculation because either no catalogues in their 
countries were present in the Lumiere VOD data or because the sample of titles from these countries for which producer data was 
available was below 10. 

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sales/distribution, as well as the footprint and exclusivity strategies of the services to which content is being 
sold.206 207 

Figure 20: Average catalogue presence of content and share of domestic catalogues by country of 
first producing company’s country (base 1 832 titles) 

Catalogue presence of content by first producers' country

 35.0

 30.0

 25.0

 20.0

 15.0

 10.0

 5.0

 -

45.0%

40.0%

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

PT

CZ

NL

IT

PL

ES

FI

AT

FR

SE

DE

BE

GB

IE

DK

Average number of catalogues content circulates in

Average share of domestic catalogues in which content is distributed

It  has  to  be  noted  that  this  comparison  looks  at  averages  and  shares  of  content  circulation  for  films  and 
television that has already successfully circulated on VoD and does not reflect countries’ and producers’ actual 
output  of  films  and  series  or  share  of  content  present  in  catalogues.  In  other  words,  countries  as  well  as 
companies  of  different  sizes  may  be  producing  a  lot  more  material  than  what  has  been  identified  as 
successfully circulating on VoD.  

Ownership and content circulation patterns of 143 top producers 

The ownership structures of producers affect their business models because they determine their access to 
specific  markets,  their  levels  of  integration,  their  possibilities  for  advantages  of  scale  and  scope  and  their 
opportunities for exploiting rights to the content they (co-)produce.208 In the dataset of the 143 companies for 
which  ownership  structures  were  assessed  common  types  of  final  owners  were  media  corporations, 
telecommunication  companies,  holding  companies,  public  bodies  and  conglomerations  of  independent 
production companies (so-called ‘super-indies’). Standalone companies have no corporate owner. The graph 
below (Figure 22) shows the distribution of these different types of ownership in the dataset. 

Of the 143 producers listed in the TMDB database that were involved in (co-)producing at least five titles in 
2020/2021  with  VoD  distribution  29%  were  public  service  broadcasters  or  owned  by  subsidiaries  of  public 
service  broadcasters,  while  28%  could  be  classified  as  standalone  companies  or  very  small  clusters  of 
independent production companies. Given the prevalence of small companies in the larger dataset, we can 
expect that the share of such standalone companies or small clusters among European producers is much 
larger.  14%  of  companies  were  owned  by  public  bodies.  This  category  mostly  represents  film  funds,  film 
institutes and local/regional screen agencies which invest in productions (e.g. CNC, Swedish Film Institute, 

206 See: Bengesser, Cathrin; Toft Hansen, Kim (2022): Scandinavian success as European policy dilemma: creative Europe’s funding 
for TV drama co-productions, 2014-20. In International Journal of Cultural Policy 28 (6), pp. 697–714. DOI: 
10.1080/10286632.2021.2022653. 

207 BG, CY, EE, GR, HR, HU, LT, LU, LV, MT, RO, SI, SK have been taken out of this calculation because either no catalogues in their 
countries were present in the Lumiere VOD data or because the sample of titles from these countries for which producer data was 
available was below 10. 

208 See: Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability 
and the digital challenge. Basingstoke: Palgrave Macmillan, p. 194-195. 

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Screen Ireland), but also includes the State-owned production company Cinecitta Luce or public educational 
institutions such as the Film & TV School of Performing Arts in Prague.  

11% of the top producers could be classified as partially or fully owned by large media corporations, namely 
Vivendi  (FR),  Gaumont  (FR),  Pathé  (FR),  Mediawan  (FR),  CGR  Cinema  (FR)  Bertelsmann  (DE),  Planeta 
Corporación  (ES),  Bonnier  (SE),  Egmont  (DK),  MediaForEurope/Mediaset  (IT),  Warner  Bros.  Discovery 
(US).209 In many cases, these corporations also own private broadcasters.210  

7%  of  the  companies  analysed  in  more  detail  could  be  classified  as  being  owned  by  Telecommunications 
corporations, namely Orange (FR), Telefonica (ES), Enodia (BE), Comcast (US), which again may also own 
broadcasters or other media corporations.  

5%  of  companies  were  owned  by  investors  or  holding  companies  with  either  a  focus  on  media  and 
entertainment  (e.g.,  Highlight  Entertainment,  owner  of  Constantin  Film)  or  a  broader  portfolio  (e.g.  Voltaire 
Finance,  owner  of  Wild  Bunch).  The  companies  owned  by  holding  companies  may  themselves  hold  more 
production companies and therefore overlap with the last category of super-indies, which are conglomerations 
of several independent production companies and distributers.  

The remaining 5% of companies either had mixed ownership or could not be classified.  

Only 5.6% of the 143 top producers of EU27+UK content with VoD distribution in this dataset are owned by 
US corporations. This finding is in line with the EAO’s recent analysis that TV production remains a European-
driven business.211  

Figure 21: Ownership of companies with at least 5 (co-)productions in 2020/2021 with VoD distribution 
(base 143 companies) 

Ownership of companies

45

40

35

30

25

20

15

10

5

0

41

40

20

16

10

7

4

3

2

PSB (incl. Their
commercial
subsidiaries)

Standalone

Public body

Media Corporations Telecommunication Holding companies

Super-Indie

Mixed

NA

or investors

209 The European Audiovisual Observatory provides a detailed analysis of the top players in the European AV business and their 
ownership. Ene, Laura (2023): Top players in the European AV industry. Ownership and Concentration. EAO. Strasbourg. Available 
online at https://rm.coe.int/top-players-in-the-european-av-industry-2022-edition-l-ene/1680a9cb32. 

210 For an account of how many broadcasters are owned by the leading AV groups in Europe see: Ene, Laura (2023): Top players in the 
European AV industry. Ownership and Concentration. EAO. Strasbourg. Available online at https://rm.coe.int/top-players-in-the-
european-av-industry-2022-edition-l-ene/1680a9cb32, p. 24. 

211 Ene, Laura (2023): Top players in the European AV industry. Ownership and Concentration. EAO. Strasbourg. Available online at 
https://rm.coe.int/top-players-in-the-european-av-industry-2022-edition-l-ene/1680a9cb32, p. 17. 

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Data  on  company  size  as  estimated  by  Orbis  (Figure  23)  was  only  available  for  two-thirds  of  the  143  top 
producers analysed in detail.212 Naturally, large and very large companies are over-represented in the sample 
of top producers, because of their higher output possibilities compared with small producing businesses. 

Figure 22: Distribution of company sizes in the dataset of 143 companies with at least five (co-) 
productions in 2020/2021 with VoD distribution 

11%

15%

23%

20%

31%

S M L

XL N/A

Table 23: Comparison of average content circulation among the top producers by business model 

Public Service 
Broadcasters (PSB) 
Producers in diversified 
media groups 
Super-Indies 

Partially integrated 
producers 
Independent producers 
without integration 
Financial services 

Public Film Support (film 
funds/screen agencies) 
Other 

Average catalogues their first 
produced content circulates in 
12.9 

23.7 

38.8 
19.5 

15.1 

77.7 
22.5 

5 

Average number of countries their 
first produced content circulates in 

4.8 

7.3 

10.9 
7.4 

6.5 

15.7 
5.8 

8 

Looking  at  the  circulation  of  content  from  the  different  types  of  producers  among  the  143  top  producers 
analysed, a correlation between higher levels of integration and greater circulation of content across countries 
and catalogues becomes evident (Table 23). The new first produced content of public service broadcasters 
circulates the least both in terms of catalogues and countries. There are a couple of possible explanations for 
the limited circulation of PSB first-produced content. Public service broadcasters are mostly nation-focused 
both in their VoD services’ footprints (see section 4.2.1) as well as in their remits charging them with producing 
programmes  of  relevance  for  the  national  communities  they  are  active  in.  Their  remits  usually  also  charge 
PSBs to offer a broad variety of genres. This materialises, for example, in PSBs’ greater focus on factual forms 
including news and current affairs, which are not as relevant for export as fiction films and series dominating 
global  SVoDs’  content  offer. 213  Publicly  funded  PSBs  may  further  restrict  the  circulation  of  their  new 

212 Particularly data on the estimated size of public service broadcasters was missing. We can, however, expect that they would be 
classified as large or very large companies. 

213 In April 2021, the Netflix catalogue in the UK comprised just 5.8 per cent factual content, which includes documentary, news, and 
current affairs (see: Ofcom 2021: Media nations: UK 2021. https://www.ofcom.org.uk/__data/assets/pdf_file/0023/222890/media-
nations-report-2021.pdf), while between August 2018 and 2020, the catalogue of the BBC iPlayer contained on average 33.6 per cent 
factual content (see: Kelly, J. P. (2021). ‘Recommended for you’: A distant reading of BBC iPlayer. Critical Studies in Television: The 
International Journal of Television Studies, 16(3), 264–285. https://doi.org/10.1177/17496020211024201). On the Danish PSB DR TV, 
for example, fiction accounted for only 28% of content hours offerend on VoD in 2021 (see: Danmarks Radio 2023: DR’s public service 
redegørelse 2022, https://www.dr.dk/om-dr/fakta-om-dr/public-service-redegoerelser). 

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commissioned  content  on  commercial  platforms  in  domestic  markets  so  as  not  to  create  a  situation  where 
audiences are made to ‘pay’ commercially for publicly funded content.214 

Content  from  producers  in  fully  or  partially  integrated  ownership  structures  (producers  in  diversified  media 
groups, super-indies, partially integrated producers) have a higher circulation of content than non-integrated 
independent  producers.  In  particular  super-indies,  which  usually  combine  production  and  B2B  distribution, 
achieve high levels of circulation, though  it should  be noted that this circulation pattern is only  based on a 
sample of 20 first productions. The high circulation of content from producers specialised in financial services, 
some of which have B2B distribution, indicates that their investments appeared to be tied to projects with high 
circulation potential. It should be noted that all the financial services companies in the dataset originate from 
the  UK,  i.e.,  a  country  where  content  has  high  circulation  potential  because  of  the  English  language.  The 
connection between production business models and circulation opportunities is discussed in more detail in 
the description of the production business models below.  

Description of seven types of producers and their business models among 143 top producers 

Public Service Broadcasters (PSB). Public service broadcasters (publicly and commercially funded)215 and 
their subsidiaries acted as first producers of 58% of the 903 titles produced by the 143 companies analysed in 
detail.  The  PSB  for  which  company  size  data  was  available  were  mainly  classified  as  very  large  or  large 
companies. 216  The  EAO’s  analysis  of  fiction  production  indicates  that  the  prevalent  role  of  PSB  in  the 
production market is that of commissioners. While public service broadcasters produced 14% of fiction titles 
in Europe between 2016 and 2020,217 they acted as commissioners for 57% of fiction productions in 2020.218 
Unscripted content may be produced in-house to a larger extent. As shown in the analysis of investments by 
PSB  in  section  4.2      ,  the  majority  of  their  investments  in  scripted  content  are  commissioned  by  external 
producers.  As  commissioners  of  content,  PSB  are  the  strongest  financial  driving  force  on  the  production 
market.219  

PSB focus mainly on the distribution of content to consumers via broadcasts, VoD and other online media. As 
shown in the analysis of business models in distribution, 64% of broadcaster-born VoD services are run by 
PSB. Despite their focus on distribution to consumers, in particular bigger PSB are also active in other areas 
of the value chain through commercial subsidiaries that own production companies and are active in the rights 
trade. ZDF Studios, the commercial subsidiary of German PSB ZDF, for example, owns production companies 
(e.g., Network Movies) and is active in rights distribution and international co-production. Similarly, RAI owns 
the distributer and producer 01 Distribution. PSB subsidiaries are also active in the co-production of films (e.g., 
BBC Films, Arte France Cinema), where they act as investors in productions by independent players.220 Yet 
the content needs of PSB, both in volume and type of productions, are much larger than what can be supplied 
in-house. Furthermore, their varying remits and strategies may limit their activities in other areas of the value 
chain.  

The  2020/21  productions  that  could  be  identified  as  (co-)produced  by  PSB  circulated  on  average  in  13 
catalogues across five countries. 42% of the content first produced by PSB circulated in only one country. As 
shown in the analysis of business models in distribution, the European broadcaster-born services are mostly 
oriented towards single countries or same-language regions. Moreover, PSB’s broader content offer beyond 
fiction, their nation-focused and in most cases non-commercial remits limits their export orientation. Still, co-

214 See for example the BBC’s Terms of Trade which stipulates an 18 month window of exclusivity in the UK and thereafter requires the 
BBC’s consent to sell to other services. See: https://variety.com/2022/tv/global/pact-bbc-secondary-sales-netflix-amazon-disney-
1235306738/. 

215 For details on the distribution of funding sources among European PSBs see: EBU (2022): FUNDING OF PUBLIC SERVICE MEDIA. 
Public Version. European Broadcasting Union. Available online at 
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/login_only/funding/EBU-MIS-Funding_of_PSM_2021_Public.pdf.  

216 XL (39%), L (20%), M (5%), S (0%), N/A (37%). 

217 Ene, Laura (2023): Top players in the European AV industry. Ownership and Concentration. EAO. Strasbourg. Available online at 
https://rm.coe.int/top-players-in-the-european-av-industry-2022-edition-l-ene/1680a9cb32, p. 17. 

218 Fontaine, Gilles (2022): Audiovisual fiction production in Europe. 2020 Figures. Available online at https://rm.coe.int/audiovisual-
fiction-production-in-europe-2020-figures/1680a5d715, p. 8. 

219 See section 3.4 Investment in European Works and the Rights market for PSBs’ commissioning budgets. 

220 In some countries direct investment into film is part of their public service remit. See: https://rm.coe.int/public-financing-for-film-and-
television-content-the-state-of-soft-mon/16808e46df  

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production  networks,  particularly  among  PSB  from  small  countries  can  play  a  major  role  in  fostering  the 
circulation of PSB content in Europe.221  

Producers  in  diversified  media  groups.  Among  the  143  producers  analysed  in  detail  20%  have  been 
classified  as  belonging  to  diversified  media  groups,  accounting  as  first  producers  for  12%  of  the  903 
productions. They tend to be classified as large or very large companies, but the category also encompasses 
small companies with very large corporate owners.222 The large media groups active in Europe all have stakes 
in production both through their own in-house broadcasters or owned production companies (e.g. TF1 Films, 
Sky Original Productions) as well as through the acquisition of independent production houses (e.g. Wildside 
acquired by Bertelsmann-owned Fremantle Media in 2015). The biggest diversified media groups in terms of 
their  share  of  the  production  of  fiction  titles  are  Mediawan,  RTL  Group  (Bertelsmann),  Warner  Brothers 
Discovery (AT&T), Bouygues and Groupe Canal+ (Vivendi).223  

The subsidiaries of diversified media groups cover the entire value chain of content production and distribution 
to  consumers  through  broadcast  or  VoD.  Vertical  integration  of  companies  along  the  value  chain  creates 
benefits such as efficiency savings, more security in content supply, a spread of risks across several business 
sectors and, potentially, also larger control over creative decisions, although it does not automatically follow 
that corporate owners of producers exert direct influence over content production.224  Groupe Canal+ (Vivendi) 
is  a  notable  example  of  integration  along  the  value  chain  and  geographical  spread,  since  it  combines  the 
financing, production and B2B distribution of films and TV through Studiocanal with the ownership of a total of 
113 TV channels and 64 VoD services225 and business activities in over 20 European territories.226 According 
to Christopher Meir, these high levels of integration, combined with a strategic focus on commercial success 
and  international  markets,  has  turned  Studiocanal  into  a  pan-European  studio. 227 However,  despite  their 
expansion  into  different  markets,  the  large  AV  groups  in  Europe  usually  remain  driven  by  one  leading 
activity.228 

A  stakeholder  representing  European  producers  further  explained  in  the  interviews  that  the  decisions  of 
integrated companies tend to be more based on perceptions of audience demand than those of independent 
players. Another stakeholder from the film industry further pointed out that productions from within integrated 
companies often benefit from large promotion budgets which may not only affect revenues but also the award-
winning potential of films.   

Still, it is important to note that that corporations can combine all elements of the value chain “in house”, but 
the subsidiaries may well still act as independent suppliers to third parties, e.g., when a production company 
that is part of a vertically integrated media corporation produces content, on a commissioned basis for a third 
party.  An  indication  of  the  scale  of  such  disintegration  of  the  value  chain  is  the  fact  that  12%  of  fiction 
productions in 2020 were produced by production groups affiliated with a broadcaster but working for a third-
party broadcaster.229  

With an average circulation of their content in seven countries and 24 catalogues the content of producers in 
large media corporation circulates more widely than that of PSB and their subsidiaries. Their own distribution 

221 See: Antoniazzi, Luca; Bengesser, Cathrin Helen (2022): Media-political inroads for Europeanising national cultural public spheres: 
EU-level obstacles and national public service perspectives. In International Journal of Cultural Policy, pp. 1–17. DOI: 
10.1080/10286632.2022.2043288. 

222 XL (29%), L (29%), M (7%), S (25%), N/A (18%). 

223 Ene, Laura (2023): Top players in the European AV industry. Ownership and Concentration. EAO. Strasbourg. Available online at 
https://rm.coe.int/top-players-in-the-european-av-industry-2022-edition-l-ene/1680a9cb32, p. 27. 

224 Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the 
digital challenge. Basingstoke: Palgrave Macmillan (Palgrave global media policy and business), p. 142. 

225 Ene, Laura (2023): Top players in the European AV industry. Ownership and Concentration. EAO. Strasbourg. Available online at 
https://rm.coe.int/top-players-in-the-european-av-industry-2022-edition-l-ene/1680a9cb32, p. 24-25. 

226 Ene, Laura (2023): Top players in the European AV industry. Ownership and Concentration. EAO. Strasbourg. Available online at 
https://rm.coe.int/top-players-in-the-european-av-industry-2022-edition-l-ene/1680a9cb32, p. 35. 

227 Meir, Christopher (2019): Mass Producing European Cinema. Studiocanal and Its Works. New York, NY: Bloomsbury Academic. 

228 Ene, Laura (2023): Top players in the European AV industry. Ownership and Concentration. EAO. Strasbourg. Available online at 
https://rm.coe.int/top-players-in-the-european-av-industry-2022-edition-l-ene/1680a9cb32, p. 11. 

229 Fontaine, Gilles (2022): Audiovisual fiction production in Europe. 2020 Figures. Available online at https://rm.coe.int/audiovisual-
fiction-production-in-europe-2020-figures/1680a5d715, p. 9. 

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activities across multiple countries make it likely for their content to be placed across the different countries in 
which the groups are active. Their larger geographical footprints also facilitate coordinated promotional efforts. 
In addition to this, the rights distributors integrated into their corporate families, as well as partnerships with 
broadcasters  and  services  not  competing  in  the  same  territories  facilitate  the  distribution  of  their  content 
beyond their own footprint. The long-running output deal between Sky and HBO is exemplary here, but an 
expansion of HBO Max into Sky territories may end this collaboration.230 

Super-indies. Super-indies are conglomerates of independent production companies that operate with varying 
levels of independence in their corporate group.231 The super-indies in the dataset were all classified as very 
large or large companies.232 Super-indies are distinct from production companies in diversified media groups 
in that they do not have stakes in distribution to consumers or other media businesses such as publishing. 
Therefore, their focus in the value chain is more distinctly on production and B2B rights trade. The acquisition 
of production companies provides a means of spreading risk, maintaining access to talent and diversifying the 
content portfolio233 as well as an opportunity to increase the company’s share in domestic and international 
markets. Big European super-indies include Banijay (FR), Beta Film (DE), Constantin Film (DE), All3Media 
(GB) and Asacha Media (FR). Banijay, for example, unites over 120 production and rights distribution labels 
and is active in 21 territories globally.234 Its companies produce and distribute fiction, children’s TV as well as 
reality  and  entertainment  formats.  Similar  to  large  media  corporations,  super-indies  may  have  access  to 
scripted and entertainment formats which their productions houses can adapt in their territories of activity.235  

The content produced by companies identified as super-indies among the 143 companies analysed in detail 
circulated even more widely than that of producers within large media groups. On average super-indie content 
circulated in 11 countries and 39 catalogues. This wider distribution of content suggests that the wide territorial 
market access of super-indies and synergies between production and B2B distribution without consideration 
of the strategic considerations of specific broadcasters or VoD services helps to further boost the dissemination 
of their content. 

Partially integrated producers. This category of companies combines activities in either production and B2B 
distribution or production and distribution to consumers but does so outside the larger corporate structures of 
super-indies  or  media  corporations.  The  dominant  company  size  in  this  group  of  top  producers  is  large  to 
medium-size.236 This type of producers acted as first producers on 9% of the productions in the sample of the 
output of top producers. Examples of partially integrated producers are: Haut et Court (FR), which combines 
production and B2B distribution; Broadview (DE), a specialised documentary producer with its own distribution 
wing; Lucky Red (IT), which acts as a producer of films and videos and owns a majority stake in the Italian 
arthouse cinema chain Circuito Cinema; or Dogwoof (GB), another specialised documentary producer with its 
own rights distribution and its own VoD service that was launched during the Covid-pandemic to supplement 
the cinematic, TV and VoD distribution of its content;237 uMedia (BE), which specialises in financing, production 
and  post-production.  Companies  combining  production  and  distribution  benefit  from  higher  margins  on  the 
exploitation of their content’s rights across several distribution windows, a steady supply of content that can 

230 Ravindran, Manori (2021): Sky Rolls Out 125 Films and TV Shows in 2021, Plans for Future Without HBO Output Deal. Available 
online at https://variety.com/2021/film/global/sky-cinema-2021-slate-hbo-peacock-1234891089/. 

231 Doyle et al. define Super-Indies as ”clusters of independent production businesses or ‘labels’ operating, with levels of autonomy that 
vary from one group to another, under the collective ownership of a consolidated parent companies.” Doyle, Gillian; Paterson, Richard; 
Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the digital challenge. Basingstoke: 
Palgrave Macmillan (Palgrave global media policy and business), p. 7. 

232 The exception is the Italian production company Ascent Film (M), which is however part of the Banijay-owned Groenlandia Group. 

233 Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the 
digital challenge. Basingstoke: Palgrave Macmillan, p. 149. 

234 See: https://www.banijay.com/our-story/ 

235 See: Keinonen, Heidi (2018): The power of the format catalogue. In Critical Studies in Television 13 (2), pp. 153–168. DOI: 
10.1177/1749602018763697. 

236 XL (11%), L (42%), M (37%), S (5%), N/A (5%). 

237 Corvin, Anne-Marie (2021): Doc Sales Agents Switch from Acquisition to Financing and Co-Pros as Feature Length Doc Slates Fill 
Up. Available online at https://variety.com/2021/film/festivals/doc-sales-agents-switch-from-acquisition-to-financing-and-co-pros-as-
feature-length-doc-slates-fill-up-1235015842/. 

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be  marketed  to  broadcasters,  VoD  services  and  cinemas,  and  knowledge  exchanges  between  the  two 
business areas.238  

While not constituting their main activity, stakes in other business activities such as distribution to consumers 
or specialised production services enable the producers to tap into supplementary income streams and create 
additional paths for the circulation of their content. On average, the content of partially integrated producers 
circulated in 19.5 catalogues across seven countries.  

Independent  producers  without  integration.  This  category  designates  stand-alone  companies  that  are 
active purely in production and have not expanded into other areas of the value chain. In the dataset of the 
143 producers with at least five 2020/21 co-productions in VoD circulation this type of producer accounted for 
7% of first productions. It  is to be expected that this type is far more prevalent  in the European production 
sector. In this category among the top producers small, medium and large-sizes were more or less equally 
prevalent.239  

Examples  of  non-integrated  independents  include:  Tornasol  pictures  (ES),  Artémis  Productions  (BE), 
Endorfilm (CZ), Snowglobe (DK). In this category it is common to see a form of specialisation, e.g., in Horror 
films (Jagged Edge, GB), films with or by female creatives (Millstreet, NL), or films with a portfolio of specific 
directors  (Versus  Productions,  BE).  According  to  Doyle  et  al.  producers  that  are  not  integrated  into  larger 
corporate structures with activities along the value chain have limited potential for organic growth, because 
they cannot benefit from economies of scale and advantages in market access and knowledge that come with 
integration.240 In the interviews, a stakeholder from the European film industry furthermore raised the issue of 
the limited budgets of independent producers for the promotion of their films which affects their possibilities to 
raise revenues and build the reputation needed to win awards. Another stakeholder representing European 
producers further perceived a tendency among independents not to focus their productions purely according 
to audience demand, resulting in less business-driven, but possibly more creatively diverse content.  

The content produced by non-integrated producers achieved an average circulation in 6.5 countries and 15 
catalogues. This is lower than the circulation of content from partially integrated producers which often have 
distribution wings. A stakeholder representing European producers explained in the interview that the levels 
of financial risks are higher for the companies outside larger corporate structures, which ideally is rewarded by 
ongoing  revenue  streams  if  the  production  is  successful  on  the  market.  As  explained  by  a  stakeholder  in 
production, during the interviews, the circulation of the works of independent producers is not just a matter of 
making the content accessible to audiences, but it also has an impact on content financing, since distributors 
contribute  to  a  project’s  budget  in  exchange  for  distribution  rights  if  they  see  potential  for  a  production’s 
circulation. Therefore, the rather limited circulation of the content of non-integrated producers may be indicative 
of the limited possibilities of attracting distributor investment.   

Public  Film  Support  (film  funds/screen  agencies).  17  companies  within  the  dataset  of  143  producers 
represent  publicly  owned  film  funds  or  local/regional  screen  agencies.  As  co-producers  they  have  been 
involved  in  225  film  productions.  According  to  a  recent  EAO  report  on  film  financing  the  direct  public 
investment, as provided by pan-European, national and local/regional film funds in this category, accounts for 
around a quarter of the budgets of fiction films.241 The national film funding bodies of big countries CNC (FR), 
MiC (IT), PISF (PL) have been involved in over 40% of these film productions. As reported by the EAO’s report 
on film financing, in particular producers in smaller markets depend on the public financing of films.242 Public 
financers from smaller countries present  among the top-producers in the sample include: Film I  Väst (SE), 
Screen Ireland (IE) and the Danish Film Institute (DK). 

Financial  services.  A  small  set  of  producers  with  involvement  in  5  or  more  2020/21  productions  has 
specialized in matters of financing areas around production; all of them are located in the UK. Ingenious Media 

238 Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the 
digital challenge. Basingstoke: Palgrave Macmillan, p. 152-153. 

239 XL (0%), L (27%), M (32%), S (27%), N/A (14%). 

240 Doyle, Gillian; Paterson, Richard; Barr, Kenny (2021): Television production in transition. Independence, scale, sustainability and the 
digital challenge. Basingstoke: Palgrave Macmillan, p. 195. 

241 Kanzler, Martin (2022): Fiction film financing in Europe: A sample analysis of films released in 2020. Available online at 
https://rm.coe.int/fiction-film-financing-in-europe-2022-edition-m-kanzler/1680aa189b, p. 40. 

242 Kanzler, Martin (2022): Fiction film financing in Europe: A sample analysis of films released in 2020. Available online at 
https://rm.coe.int/fiction-film-financing-in-europe-2022-edition-m-kanzler/1680aa189b, p. 50. 

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(GB) acts as an investor into film and TV and other creative industries, but also real estate, infrastructure and 
education.243 Another example is Hanway Film, which engages in financing as well as B2B distribution of film. 
The four companies in this category were first producers on only 21 productions. However, these productions 
circulate widely with an average presence in 15.7 countries and 77.7 catalogues. This circulation is far above 
the average circulation for UK first-produced content (8.3 countries and 26.5 catalogues). The wide circulation 
of content with the involvement of dedicated financers, some of which act as rights distributors, indicates that 
their  business  appears  to  be  driven  by  content  that  can  achieve  wide  circulation,  which  British  content  is 
predestined for through English as a language of advantage.   

Film Schools. Three companies in the sample of 143 producers were film schools (two public, one private).  

Other.  Three  companies  could  not  be  conclusively  placed  within  either  of  the  categories  described  above 
because no sufficient knowledge on their activity was available.  

4.3    

Investment in European works and the rights market 

Overall, our mapping of PSB in the eight EU countries shows that investments in independent works remained 
stable or increased in 2020-2021, while others e.g., Česká televize (Czechia) and ZDF (Germany) reduced 
their investments.  

Our  findings244 show  that  cutbacks  at  the  level  of  public  broadcasting  have  not  necessarily  led  to  reduced 
investments  in  original  programming.  Based  on  available  data,  we  also  noted  that  investment  in  European 
works  represents  an  important  part  of  the  total  investment,  and  that  most  of  the  investments  in  scripted 
content245 are  made  through  commissioning246.  Investing  in  films  has  traditionally  been  part  of  the  remit  of 
various  public  broadcasters,  and  data  from  the  European  Audiovisual  Observatory  (EAO)  suggests  that 
broadcasting  investment  still  accounts  for  approximately  20%  of  total  investment  in  films,  yet  for  some 
broadcasters, such as the Flemish VRT, it has disappeared as a core part of the remit of the public broadcaster, 
in all likelihood due to budget prioritisation and the significant investment in other local content.  

The sections below present a breakdown of PSB in each case study: Belgium, Czechia, France, Germany, 
Italy, the Netherlands, Poland and Sweden. The data provided is as granular as available. For example, for 
some countries there is data available for 2020, but not for 2021; or some countries do not differentiate between 
acquisition of rights and commissioning247. Regarding data sources, the team used data provided (i) by PSB 
themselves in annual reports, usually including data on direct investments in programmes; and (ii) by National 
Regulatory  Authorities  (NRAs).  The  EAO  provides  a  breakdown  of  broadcaster  investments  in  original 
production  by  statute  (public  vs.  private,  from  2011  to  2021).248 The  European  Broadcasting  Union  (EBU) 
publications  database  lists  several  potentially  useful  reports  that  could  contain  relevant  data  on  PSB 
investments.  However,  the  identified  reports  are  EBU  exclusive  content  and  are  only  available  to  EBU 
Members (i.e., EBU Member, Associate or Approved Participant). The public versions of these reports, when 
available, are summarised versions of the originals, often aggregating data relevant to this study.249 

243 See: https://www.theingeniousgroup.co.uk/our-story/ 

244 Generalisations or accurate comparisons between countries, typologies of content/genre are not possible based on the data obtained 
as programmes differ from one country to another and possibly (e.g., within one country) from one broadcaster to another. Even for a 
given broadcaster, there can be changes from one year to the next, which may limit comparison possibilities (see, e.g. ZDF).  

245

 Scripted content in this report is content that has a predetermined script per episode and/or season, covering a wide range of genres, 
including drama, comedy, science-fiction, and crime, among others. There are variations in the use of the term in practice and reporting 
that needs to be taken into consideration when analysing investments. 

246 In this section, wherever possible, we made a distinction between commissioning and acquisition of rights. We did not where data 
was not available and/or the distinction not clearly made. While there are variations among the countries (or even, within a country, 
among PSB), commissioning corresponds to amounts invested to have content produced, internally or externally (e.g., by an 
independent producer, or in a co-production); acquisition of rights corresponds to the purchase of already made content, it can also be 
called licensing of rights. 

247 See previous note. 

248

 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 

https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe  
249 European Broadcasting Union (2022). The list of reports and publications of interest are available at:  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/country_profile/EBU-MIS-Country_Profile_2022-The Czechia.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/country_profile/EBU-MIS-Country_Profile_2022-Germany.pdf  

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Belgium (BE) 

French-speaking community - RTBF 

in mln EUR 

2020 

2021 

Investments in programmes, of which: 

33.8 

34.5 

Acquisition of rights (to broadcast) 

Commissioned productions (investment in co-productions) 

Source: RTBF250  

n/a 

n/a 

25 

9.6 

RTBF’s 2021 annual report shows a slight increase of 2.4% in the broadcaster’s direct investments in fiction 
and documentaries from EUR 33.8 million in 2020 to EUR 34.6 million in 2021. In general, RTBF increased 
investments in programmes from EUR 178.9 to 200.8 million from 2020 to 2021. In 2021, acquisition of rights 
accounted for 72.3%, and commissioned productions for 27.7% of these investments. A breakdown for 2020 
is not available. 

in hours per day (average) 

Broadcast of own production 

Source: CSA251  

2019 

33h54 

2020 

31h59 

The  CSA  (the  NRA  for  the  French-speaking  part  of  Belgium)  provides  complementary  data  in  its  annual 
assessment of the RTBF.252 This includes data regarding direct investments in 2019 and 2020, time devoted 
to broadcasting its own production, amounts invested in independent production. 

Dutch-speaking community – VRT 

in millions of EUR 

Investments  

2020 

62.1 

2021 

80.1 

https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/country_profile/EBU-MIS-Country_Profile_2022-France.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/country_profile/EBU-MIS-Country_Profile_2022-Italy.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/country_profile/EBU-MIS-Country_Profile_2022-Netherlands.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/country_profile/EBU-MIS-Country_Profile_2022-Poland.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/country_profile/EBU-MIS-Country_Profile_2022-Sweden.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/market_insights/EBU-MIS-PSMs_Competitive_Environment_2022.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/psm/EBU-MIS-Entertainment_PSM_2022.pdf  
https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/members_only/psm/EBU-MIS-PSM_Contribution_to_the_European_Creative_Sector_2022.pdf  

250 RTFB (2021). Rapport annuel. RTBF.be. Note: The data included corresponds to investments in fiction and documentaries. The 
report also provides data on investments in 2020 and 2021 for the following types of content (not included here): news and sport, 360 
production, thematics, “les contenus”. 

251 CONSEIL SUPERIEUR DE L’AUDIOVISUEL (2021). RTBF – AVIS 2020. CONSEIL SUPERIEUR DE L’AUDIOVISUEL. 

252 Idem. 

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Source: VRM253 254 

The VRT’s direct investments have increased by 29% from 62.1 in 2020 to 80.1 million EUR in 2021. These 
data are provided by the VRM (the NRA for the Flemish Community of Belgium) in its annual monitoring of the 
VRT's compliance with the management agreement it has with the Flemish Community of Belgium255. In 2021, 
this included the investment in 16 documentaries. 

According to  the VRT  management contract,  a  minimum  of 20% of the total budget has to be  allocated to 
independent  production,  with  500,000  going  to  independent  audio  production.  There  are  no  specific  genre 
requirements for investment in fiction series. With regard to scripted content, VRT aired 13 of the total of 22 
fiction projects in Flanders in 2020; in 2021, 17 out of 29 total scripted projects; in 2022, 11 out 23. According 
to the VRT management contract, VRT is required to invest annually in a minimum of 15 documentary episodes 
(of which a minimum of eight authored documentaries, one-off documentary films or episodes of a series). 

Czechia (CZ) 

Česká televize 

in millions of EUR 

Investments in programmes (of which:) 

Acquisition of rights (to broadcast) 

Commissioned productions 

Source: Česká televize256  

2020 

34 

9.53 

24.46 

2021 

32.6 

9.61 

22.99 

Česká televize’s direct investments decreased by 4.1% from EUR 34 million in 2020 to EUR 32.6 million in 
2021. These data are provided by Česká televize in its annual report.257 

France (FR) 

France Télévision 

in millions of EUR 

Commissioned productions 

Source: Legifrance258  

2020 

482.30 

2021 

500 

253 VLAAMSE REGULATOR VOOR DE MEDIA (2021). RAPPORT 2021. Toezicht op de naleving door de openbare omroep van de 
beheersovereenkomst met de Vlaamse Gemeenschap. VLAAMSE REGULATOR VOOR DE MEDIA. Note: These values correspond to 
the total spending in the Flemish audiovisual production sector. 

254 VLAAMSE REGULATOR VOOR DE MEDIA (2020). RAPPORT 2021. Toezicht op de naleving door de openbare omroep van de 
beheersovereenkomst met de Vlaamse Gemeenschap. VLAAMSE REGULATOR VOOR DE MEDIA. 

255 VLAAMSE REGULATOR VOOR DE MEDIA (2021). RAPPORT 2021. Toezicht op de naleving door de openbare omroep van de 
beheersovereenkomst met de Vlaamse Gemeenschap. VLAAMSE REGULATOR VOOR DE MEDIA. Note: These values correspond to 
the total spending in the Flemish audiovisual production sector. 

256 Česká televize (2021). Výroční zpráva o hospodaření České televize v roce 2021. Česká televise. Note: Acquisition of rights 
corresponds to “avkizicie”, commissioned productions to “dokument + dramatika”. The latter includes production costs incurred from 
hiring or commissioning outside talent, crews and production companies. But it does not include internal employees and infrastructures. 
Data are also available about spending for other types of content (including sport, talk shows, entertainment, news, performances, etc.). 
A comparison with a set of data provided by Ampere (which cannot be published here) shows comparable developments. 

257 Česká televize (2021). Výroční zpráva o hospodaření České televize v roce 2021. Česká televise.  

258 Legifrance.gouv.fr (2022). Avis n° 2022-14 du 7 octobre 2022 relatif au rapport d'exécution des contrats d'objectifs et de moyens de 
France Télévisions, Radio France et France Médias Monde pour l'année 2021, JORF n°0237 du 12 octobre 2022. Available at : 

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Germany (DE)  

ARD259 

In millions of EUR 

Documentary 

TV films/series 

Feature films (Degeto) 

Animation 

Source: ARD260 261 

2019 

56.1 

175.3 

213.7 

9.1 

2020 

64.4 

169.4 

275.4 

7.8 

In 2020, ARD spent a total of EUR 857.1 million on the production of commissioned, co-productions and mixed 
productions as well as on the acquisition of broadcasting rights.262 ARD’s total investments in documentaries, 
TV movies and series, feature films and animation263 amounted to EUR 517 million in 2020, an increase of 
13.81% versus 2019 (EUR 454.2 million). More granular information is provided with a breakdown according 
to genre: 

− 

− 

In  2021,  investments  in  documentaries  amounted  to  EUR  64.4  million,  i.e.,  an  increase  of  14.8% 
versus 2020 (EUR 56.1 million).  

Investment in TV films/series totalled EUR 169.4 million in 2020, i.e., down 3.4% on 2019 (EUR 175.3 
million).  

−  The highest investments were in the procurement and production of feature films, totalling EUR 275.4 

million in 2020, i.e., a 28.84% increase versus 2019 (EUR 213.7 million).  

− 

Investments in animation amounted to EUR 7.8 million in 2020, representing a 14.75% decline versus 
2019 (EUR 9.1 million). 

Information  on  the  investments  of  the  nine  regional  PSB  organisations  is  aggregated  at  the  level  of  ARD. 
Investments in commissioned content are reported annually and the two last reports available are for the years 
2020 and 2019.  

https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000046404947. Note : Rapport sur l’exécution du cahier des charges de France 
Télévisions – Année 2020. These correspond to amounts invested, in audiovisual (fiction, documentaries including regional and 
overseas, animation, live performance) and film production. 

259 ARD is the joint organisation of Germany's nine regional public service broadcasters. 

260 ARD (2020). ARD-PRODUZENTENBERICHT FÜR DAS JAHR 2020. Available at: https://www.ard.de/ard/die-ard/ARD-
Produzentenbericht-2020-100.pdf. 

261 ARD (2019). ARD-PRODUZENTENBERICHT FÜR DAS JAHR 2019. Available at: https://www.ard.de/ard/die-ard/ARD-
Produzentenbericht-2019-100.pdf. 

262 ARD’s reporting distinguishes four production types, namely commissioned, mixed, co-productions and licenced productions 
depending on the parties and the nature of their involvement (in German, respectively ‘Auftragsproduktionen’, ‘Mischproduktionen’, 
‘Koproduktionen’ and ‘Lizenzproduktionen’). Commissioned productions are produced by third parties on behalf of the respective state 
broadcaster. Mixed productions (including also Partial services for an in-house production, and Partial services for a co-production; in 
German, respectively ‘Teilleistungen zu einer Eigenproduktion’ and ‘Teilleistungen zu einer Koproduktion’) are productions in which a 
state broadcasting corporation is involved in various capacities and/or stages in a production which may include bearing overall 
production responsibility, providing production locations/sets, provision of recording/transmission technology and/or equipment, set 
props and technical staff/crews. Co-productions are productions involving one or more state broadcasters and one or more third parties. 
Licenced productions represent the purchase, i.e. the licencing of broadcasting rights for full-length programmes. 

263 The genres within the scope of the analysis were selected from among ARD’s own classification of 15 genres. Feature films are 
procured and produced by Degeto, the production and film rights trading company of ARD whose shareholders are the regional 
broadcasting corporations (i.e. the ARD). Degeto acquires fictional programmes for ARD's national TV channel, the so-called "third 
programmes" of the regional broadcasting corporations, 3sat, Arte, One and other ARD channels. Animation is a subcategory of Family 
content, which is an independent category.  

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Deutsche Welle (DW) 

in millions of EUR 

Fees and programme expenses 

Source: Deutsche Welle264 265 

2020 

147.9 

2021 

162.2 

Deutsche  Welle  is  a  German  international  broadcaster  targeting  audiences  abroad  via  satellite  TV  service 
available  in  four  languages and online service available  in  32  languages.  DW  is  owned and funded  by the 
German state. Information on investments in content is reported in the annual management report, albeit at 
the most aggregate level. 

ZDF266 

Programme expenditure according to 2021 annual accounts (source ZDF) 

(difference in classification of expenses, see categories) 

in millions of EUR 

Films 

Series 

2021 

239.4 

213.5 

Programme expenditure according to 2020, 23 KEF report (source KEF) 

(difference in classification of expenses, see categories) 

in millions of EUR 

TV Films/Series 

Films 

Source: ZDF267; KEF268 

2020 

456.1 

98.9 

ZDF’s content spend is reported annually at aggregate level as programming expenditure, which incorporates:  

−  all  content  spending  -  including  investments  in  production  of  informative,  factual  and  editorial 
programmes,  entertainment,  documentary  and  fiction  programmes,  as  well  as  investments  in 
associated or partner channels such as 3sat, ARTE, KiKA, etc.;  

−  all investments made for content delivery—terrestrial, satellite, on-demand, etc.;  

−  and all other costs associated with the production, licencing and delivery of content.  

Relative to ARD, ZDF has a different approach to reporting and transparency on content spending, an issue 
which has been raised  by the German association of producers and recognised by the public broadcaster. 
Data on ZDF’s investments can be found in the organisation’s annual accounts. However, it must be noted 
that there is a significant difference in how information regarding investments in programmes is aggregated, 
especially between the 2021 accounts and those for 2020 and 2019 which could hinder the comparison and 

264

 DW (2020). Lagebericht für das Geschäftsjahr vom 1. Januar 2020 bis zum 31. Dezember 2020. Bonn: Deutsche Welle Anstalt des 

öffentlichen Rechts. Available at: https://static.dw.com/downloads/59656207/lagebericht2020deutsch.pdf. 

265

 DW (2021). Lagebericht für das Geschäftsjahr vom 1. Januar 2021 bis zum 31. Dezember 2021. Bonn: Deutsche Welle Anstalt des 

öffentlichen Rechts. Available at https://static.dw.com/downloads/63722395/2021lageberichtdeutsch.pdf. 

266 ZDF is Germany’s second public broadcaster, founded by all German federal states and financed by licence fees and advertising 
revenues. 

267 ZDF (2021). ZDF Jahresabschluss 2020. ZDF. Available at https://www.zdf.de/zdfunternehmen/2021-jahrbuch-finanzen-
jahresabschluss-100.html. 

268 KEF (2022). KEF Bericht 23. KEF. Available at https://kef-online.de/fileadmin/KEF/Dateien/Berichte/23._Bericht.pdf. 

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analysis  of  investments  over  time.  Furthermore,  other  sources  that  could  be  used  to  corroborate  data  on 
programme investments are scarce and, when available, either rely on different classification of programming 
(genres), use programming (hours/minutes as unit of analysis), or are not available for each period (in case of 
bi-annual reporting).  

With that in mind, according to ZDF's annual account for 2021,  the broadcaster’s expenditure amounted to 
EUR 239.4 million invested in films and EUR 213.5 million in TV series. Following KEF’s (the German NRA) 
own classification, based on information supplied by ZDF, the 2020 programming expenses include EUR 456.1 
million investments in TV Films/Series and EUR 98.9 million in films. 

Italy (IT) 

RAI 

in millions of EUR 

Investments in programmes (of which:) 

Fiction/Drama 

Animation/Cartoons 

Other 

Source: RAI269 270 

2020 

175.3 

157.9 

14.5 

2.9 

2021 

231.4 

210.9 

16.9 

3.6 

In the financial statements of the Italian public broadcaster RAI, the information on investments is aggregated 
on an annual basis (i.e., total investments). RAI’s total investments amounted to EUR 340.1 million in 2021, 
an increase of 19.79% versus 2020 (283.9). More detailed information is provided with the breakdown of the 
level of total investment into technical investments (investments related to technical capacities for producing 
and broadcasting programmes), investments in lease rights of use (lease contracts for company premises) 
and investments in programmes.  

In 2021, investments in programmes amounted to EUR 231.4 million, i.e., 32% higher than in 2020 (EUR 175.3 
million).  Investment  in  programmes  includes  the  following  sub-categories:  investments  in  Fiction/Drama, 
investments  in  Animation/Cartoon  and  Other  investments.  In  2021,  investments  in  Fiction/Drama  rose  by 
33.57% to EUR 210.9 million; in Animation/Cartoons by 16.55% to EUR 16.9 million and in Other investments 
by 24.14% to EUR 3.6 million. 

Netherlands (NL) 

NPO 

in millions of EUR 

Direct costs of production 

Source: NPO271  

2020 

70.15 

2021 

68.71 

269 RAI (2021). Relazione e bilanci al 31 dicembre 2021. Rai.it. Available at: 
https://www.rai.it/dl/doc/1659485467533_Bilancio%20Rai%202021%2002-08.pdf. 

270 RAI (2020). Relazione e bilanci al 31 dicembre 2020. Rai.it. Available at: 
https://www.rai.it/dl/doc/1632746451286_Rai%20RFA%202020%20Ita%2023_09.pdf. 

271 NPO (2021). NPO Jaarverslag 2021. NPO. Note: The “directe productiekosten” notably include costs for broadcasting, licencing 
rights and costs related to marketing and audience research. A breakdown is provided for 2020 and 2021. 

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NPO’s  direct  investments  increased  by  1.12%  from  72.5  in  2020  to  73.32  million  EUR  in  2021.  The  slight 
decrease in commissioned productions was more than offset by the increase in acquisition of rights. These 
data are provided by NPO in its annual report.272 

Poland (PL) 

TVP 

TVP’s content spending is reported annually at an aggregate level described as “Costs of tasks related to the 
implementation of TVP SA’s mission”. Investments in content are divided into “programme development costs” 
and  “distribution  costs  of  programmes”.  The  costs  of  creating  programme  also  include  the  fees  payable  to 
organisations for the collective management of copyright and related rights as well as the company's general 
overheads.273 

Table 24: Annual programme development costs 

in millions of EUR 

Annual programme development 
costs 

Program 1 

Program 2 

TVP 3 and regional programmes 

TVP Polonia 

TVP Wilno 

Belsat TV 

TVP World (ex Poland IN) 

TVP Info 

TVP Kultura 

TVP Historia 

TVP ABC 

TVP Rozrywka 

TVP Seriale 

TVP Sport 

TVP 4K 

TVP HD 

TVP Dokument 

TVP Kobieta 

272 Idem.  

2020 

185.8 

110.6 

69.3 

7.4 

3.4 

9 

1.7 

36.2 

11.2 

8.3 

7.3 

1.2 

0.7 

20.2 

n/a 

2.3 

0.2 

n/a 

2021 

218.5 

148.5 

81 

8.7 

5.6 

9.1 

4.7 

35.9 

15.1 

9.9 

8.2 

0.6 

0.7 

26.7 

0.06 

2.1 

0.003 

2.2. 

273 TVP (2022). TVP Management Board report on the use of subscription revenues in 2021. Available at: 
https://s.tvp.pl/repository/attachment/9/e/8/9e881cb76f11b1e0d6b774e5fb8faa581651239693127.pdf  

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TVP multimedia offer; non-
program services 

21.4 

25.6 

The  table  below  illustrates  the  average  annual  share  of  programmes:  (1.  Originally  produced  in  Polish 
language, 2. European programmes, and 3. European programmes produced by independent producers) in 
the  annual  programme  broadcasting  time,  excluding  news  services,  advertisements,  teleshopping,  sports 
broadcasts and game shows. 274 275 

Table 25: The average annual share of programmes 

Average annual share of programmes (in %) 

Polish 
programmes 

European 
programmes 

European 
programmes by 
independent 
producers 

2020 

2021 

2020 

2021 

2020 

2021 

TVP 1 

TVP 2 

TV INFO 

TVP 3 

TVP Polonia 

TVP Kultura 

TVP Sport 

TVP Historia 

TVP HD 

TVP Seriale 

TVP Rozrywka 

TVP ABC 

TVP World (ex Poland IN) 

TVP Wilno 

TVP Woman 

Sweden (SE) 

Sveriges Television (SVT) 

in millions of EUR 

Programming expenditure 

Fiction 

Source: SVT276 

53 

55 

99 

84 

91 

55 

75 

67 

66 

83 

90 

35 

96 

88 

n/a 

59 

56 

96 

83 

84 

52 

69 

66 

71 

91 

91 

35 

57 

87 

49 

83 

81 

99 

96 

95 

92 

90 

90 

89 

98 

97 

65 

96 

93 

n/a 

85 

88 

99 

96 

94 

85 

91 

92 

89 

97 

96 

68 

99 

95 

83 

37 

31 

12 

16 

31 

41 

25 

34 

41 

55 

12 

37 

26 

29 

n/a 

39 

36 

12 

18 

36 

42 

28 

38 

45 

57 

14 

40 

25 

32 

39 

2020 

359.1 

80.8 

2021 

419.9 

85.6 

SVT classifies programming costs into programme production, distribution and common costs. There are very 
large differences in how costs are distributed for producing different programmes, as shown in the table below. 

274 Idem. 

275 TVP (2020). Avialable at: https://centruminformacji.tvp.pl/53579725/sprawozdanie-abonamentowe-tvp-za-2020-r-i-sprawozdanie-z-
realizacji-misji-publicznej-przez-tvp-w-2020-r. Note: Report on the use of subscription revenues in 2020. 

276 SVT (2022). Sveriges Televisions public service-redovisning 2021. Available at: 
https://omoss.svt.se/download/18.7e0bf94d17f44ad5cf335f2/1646138435936/PSR_uppslag_lr.pdf. 

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As outlined by SVT, the most expensive programme to produce (per hour) is quality drama and the cheapest 
is  the  purchase  of  finished  programmes  that  are  made  outside  of  Sweden  in  the  “leisure  and  social  facts” 
category. The difference can be from an hourly cost of several millions to programmes that cost under SEK 
50,000  per  hour.  A  breakdown  of  total  costs  in  2021  per  category  shows  that  22.4%  was  spent  on  fiction 
(22.5% in 2020). 

Total costs (SEK millions) (as %) 
Entertainment  Sports 
Fiction 

Culture & 
Music 

Leisure 
facts 

Science 
facts 

Social 
facts 

News 

SVT 
Forum 

Joint 

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

0
2
0
2

1
2
0
2

22.5 

20.4 

18.4 

15.2 

9.3 

20.4 

6.1 

5.4 

6.6 

6.4 

2.6 

2 

9.4 

8.9 

23.9 

20.3 

0.1 

0.1 

1.1 

0.9 

Source: SVT income and expenditures277 

4.3.1     Commercial broadcasters and pay-TV channels 

Based on a recent EAO report278, commercial (private) broadcasters significantly increased their investments 
in original European content reaching EUR 7.5 billion in 2021.279 This makes up 43% of all investments (from 
all players) in original European content. Of the EUR 7.5 billion investments by commercial broadcasters, 49% 
was invested in original productions and 51% in the acquisition of film and TV rights. Based on this, commercial 
broadcasters invested, for the first time in 2021, more in original content in Europe than public broadcasters. 
After a decrease in 2020 to about EUR 6.5 billion, investments by commercial broadcasters reached a similar 
level to pre-COVID-19 times in 2021. 

The above data represents an analysis of the Ampere database. Identifying trends across countries and based 
on data made directly and publicly available by commercial broadcasters is difficult due to the limited available 
data. The study aimed to identify insights into the investments made by commercial broadcasters through desk 
research identifying industry reports and financial reports of commercial broadcasters. However, because of 
limited obligations regarding transparency for commercial broadcasters, recent data could only be identified 
for France (based on data published by the audiovisual regulator (l'Autorité publique française de régulation 
de la communication audiovisuelle et numérique – ARCOM) in 2022 for 2020 for the first time)280.  

The  data  for  European  commercial  broadcasters’  direct  investments  in  original  European  content  (fiction, 
documentaries, game shows, talk shows, etc.) in 2020 and 2021 is shown in the table below.  

European (EU27 + UK + Norway)  

France (based on 29 commercial broadcasters and Pay-TV)  

Direct investments (billion EUR) 

2020 

6.5 

0.5 

2021 

7.5 

n.a. 

In France, commercial broadcasters are required to allocate between 5.15-15% of their net turnover for the 
acquisition,  production  or  co-production  of  European  works  (85%  of  this  for  works  of  original  French 
expression). 281 Commercial  broadcasters  are  obligated  to  report  their  direct  investments  to  ACROM,  the 
regulator, which published for the first time in 2022 a comprehensive overview of investments made by different 

277 SVT (n.d.), Available at: https://siffror.svt.se/sa-anvands-pengarna.html  

278 COE (2022), Available at: https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-/1680a75db4  

279 In the report, “Original content” refers to all categories of original works (fiction, documentaries, game shows, talk shows, etc.) and 
“European” refers to EU27 + UK + Norway. Data represents extrapolations of Ampere Analysis data. 

280 ARCOM (2020), Available at https://www.arcom.fr/mediatheque/contribution-au-developpement-de-la-production-audiovisuelle-
donnees-quantitatives-exercice-2020. 

281 Kostovska, I., Raats, T., Iordachi, C., Domazetovikj, N., Komorowski, M. (2022). Policy Brief #61: Investment obligations for VOD 
providers: Fresh look on the regulatory approaches in Europe. Brussels: VUB-SMIT. Available at https://smit.vub.ac.be/policy-brief-61-
investment-obligations-for-VoD-providers. 

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AV publishers.282 Unfortunately, no historical data is available. The table below gives information about the 
investments made. 

C8 (Groupe Canal+) 

CStar (Groupe Canal+) 

Gulli, Canal J, Tiji, La chaîne du père noël, MCM, MCM Top, 
RFM TV 

Groupe NRJ 

(NRJ12 / Chérie 25) 

Groupe M6 

RMC Découverte 

RMC Story 

Groupe TF1 

2020 (in millions of EUR) 

15 868 

2 636 

8 599 

11 429 

123 237 

17 329 

7 241 (partly made) 

192 481 (partly made) 

CANAL+ (groupe) 

58 795 (partly made) 

All pay channels (excluding groups Canal+, M6 and TF1) 

18 941 

TOTAL 

456 556 

4.3.2     Indirect investments as contributions to audiovisual funds/levies 

Based on our analysis, the European landscape in terms of indirect investments to European content through 
contributions  to  audiovisual  funds  is  highly  diverse.  Based  on  the  legislation  in  each  country,  various 
audiovisual players have to make contributions – in some countries all of them (e.g., Germany, France) and 
other countries only the PSB (e.g., the Dutch-speaking community of Belgium) or only distributors or cinemas 
(e.g.,  the  Netherlands).  However,  in  most  countries,  there  are  currently  discussions  or  plans  to  extend  the 
obligation  to  contribute  to  film  funds  to  more  players  in  the  market  (e.g.,  Czechia),  which  would  mean  a 
considerable increase in investments available for film funds in European content.  

For example, Poland (see more on this below) introduced a requirement for the payment of a levy by VoD 
players to the film fund in 2020 as part of a Covid-19 anti-crisis relief programme; in this way it increased the 
income of the fund by more than 8%. Where VoD players contribute to film funds, it is clear that the shares of 
the  overall  contributions  to  the  funds  are  considerable.  In  Germany,  for  example,  the  contributions  of  VoD 
players to the film fund are even higher than the contributions of traditional broadcasters. Where film funds 
receive contributions from cinema receipts (which sometimes represent the largest share of contributions), the 
COVID restrictions had of course a considerable impact on the  total income of the film funds, which in turn 
impacts the amount of investment available for European film. In some countries, the governments decided 
exceptionally to provide additional grants to cover these losses (e.g., France, the Netherlands). Overall, we 
can see that the contributions to film funds (and therefore the investment into European content by film funds) 
increased considerably in the period from 2020-2021. This was partly due to delayed release of films in 2021 

282 ARCOM (2020), Available at https://www.arcom.fr/mediatheque/contribution-au-developpement-de-la-production-audiovisuelle-
donnees-quantitatives-exercice-2020. 

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because of COVID or legislative changes in various countries. With the increasing revenues of audiovisual 
players investment through film funds is also indirectly increasing.  

This section below presents the case studies including the investments made by different media players as 
part of the funding requirement of audiovisual/film funds through the payment of levies and taxes. Revenue 
streams  come  from  combinations  of  public,  private  and  pay-TV  broadcasters,  cinema  exhibitors  and 
distributors,  distributors  of  television  signals,  and  domestic  and/or  cross-border  streaming  platforms.283 We 
have focused on the countries where investments in audiovisual funds or levies are required, based on the 
data available.284 

Belgium (BE) 

French-speaking  community  –  Centre  du  Cinéma  et  de  l'Audiovisuel  (CCA).  The  Centre's  existence  is 
governed by the "décret du 10 novembre 2011 relatif au soutien au cinéma et  à la création audiovisuelle". 
Articles  6.1.1-1  and  6.1.2-1  of  the  audiovisual  decree  (version  2021)  stipulate  that  TV  publishers  and  TV 
distributors have to contribute to AV production, either directly (through co-productions or pre-purchase), or 
through the CCA. Based on the CCA’s Annual Report (CCA 2021), a total of EUR 35.3 million was allocated 
to audiovisual support in Wallonia in 2021 through the CCA.  

Of this, 34% of investment (EUR 11.8 million) came from publishers and distributors of audiovisual services 
through the CCA, broken down as follows: EUR 5.6 million from the public service broadcaster, RTBF, EUR 
1.7  million  from  Proximus,  EUR  1.3  million  from  VOO,  EUR  2.3  million  from  BeTV  and  the  rest  from  other 
distributors.  Additionally,  EUR  2.1  million  of  indirect  investment  was  made  by  the  French  Community  of 
Belgium through funds to the RTBF. Compared with 2020, total investments through the CCA increased by 
approximately 10%. 

Dutch-speaking community – Vlaams Audiovisueel Fonds (VAF) 

The media fund (dedicated to supporting animation, documentary, and fiction series) receives income from the 
government, and additional income from three sources: the public broadcaster, the cross-border streaming 
platforms,  and  domestic  providers  of  television  services.  The  latter  consists  of  the  contribution  (part  of  the 
Minister of Media’s competences) from those service providers and streaming platforms that do not choose to 
invest directly in content: EUR 380 898 in 2021; EUR 345 921 in 2020. In Flanders, the investment obligation 
entails a choice between investing directly or contributing to the Flemish Media Fund. The larger players mostly 
choose to invest directly in audiovisual productions. Additionally, the Media Fund (series) receives an annual 
contribution from the public service broadcaster VRT, in the form of a capped amount from the revenues from 
advertisement  sales  (maximum  EUR  1  million  annually).  This  was  EUR  1  million  in  2020,  but  in  2021  for 
example, there was no amount top-sliced from the VRT budget. 

The film fund (part of the Minister of Culture’s competences) receives no financial input from broadcasters or 
VoD platforms. In current discussions on the reform of the investment obligations, producers are requesting 
that at least a proportion of the required investment be directed towards feature films, similar to the provisions 
in France. 

Germany (DE) - Deutsche Filmförderfonds (DFFF) 

The DFFF’s budget is drawn from a number of different sources. It is divided between the film taxes received 
from cinemas (§151 Filmförderungsgesetz – Film Funding Act - FFG), video programme providers (§152 FFG), 
VoD  service  providers  (§153  FFG),  public  television  broadcasters  (§154  FFG),  broadcasters  of  free-to-air 
television programmes under private law (§155 FFG), and the organiser of pay television and the programme 
marketer (§156 FFG) (FFA, 2021). Depending on their size, VoD players are required to contribute between 
1.8% and 2.5% of the turnover from sales of cinema films. 

283 Sources for this section include: IrisPlus database; VAF Annual report 2020; VAF annual report 2021/ VAF website; consulted 
sources at EFAD; Kostovska et al. 2022; NLFilmfonds web portal, 2022; Tuschinksifonds Annual report, 2021; Tuschinksifonds, 2022; 
CNC Rapport d’activités 2021; CNC Rapport d’activités; 2022; CCA Chiffres Clés, 2021; Arcom, 2021; SMAD Decree France, 2021; 
FFA, 2021; FFA, 2020; CFWB, 2021.  

284 This means we did not include Italy, where the audiovisual fund does not receive any investment from audiovisual players and 
players are subject to direct investment obligations instead, and Sweden, where the Swedish Film Institute is financed solely by the 
Swedish government. Additionally, Czechia is not included below as no data to report on was available after consultation with local 
stakeholders. 

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In 2021, the German film fund received EUR 69.5 million. Of this amount, EUR 3.9 million was generated by 
levies paid by cinema exhibitors, EUR 16 million came from video-on-demand players and EUR 15.9 million 
from broadcasters (free-to-air commercial, public broadcasters and pay-TV operators). Of the latter, the public 
broadcasters ARD and ZDF contributed EUR 9.7 million in 2021 (and EUR 8.8 million in 2020) (FFA, 2021). 
Private television broadcasters contributed EUR 5.1 million in 2021, and EUR 4.8 million in 2020 (including 
advance payments from two broadcasters), and EUR 5.9 million in additional payments (compared with EUR 
5.3 million in 2020) (FFA, 2021). Finally, pay-TV operators and distributors made payments of EUR 1.1 million 
to the fund in 2021. 

France (FR) – Centre national du cinéma et de l'image animée (CNC) 

The funding for the  CNC  in France  is based  on  levies and contributions from  different media players. This 
includes broadcasters, television distributors, cinema exhibitors, but also VoD players. In 2021, France’s CNC 
invested a total of EUR 799.4 million, of which EUR 184.7 million was exceptionally granted by the government 
following the impact of COVID-19. Of this, EUR 247.5 million went to films, EUR 247.1 million to the broad 
audiovisual  industry,  and  the  rest  to  various  other  actions.  In  2021,  a  total  net  of  EUR  581.8  million  was 
received from different levies from audiovisual players; the levy on cinema attendance contributed EUR 56.9 
million, the levy for broadcasters and television distributors EUR 457.4 million, the recently adopted levy for 
VoD EUR 111.6 million and others 0.01 million (CNC, 2022). 

According to CNC annual reports (2018-2021), investments received from the theatrical levy went from EUR 
146 million in 2018 and EUR 154 million in 2019, to EUR 28.5 and EUR 56.9 million, due to the Covid-related 
closing of cinemas. Income from the VoD services tax amounted to EUR 111.6 million in 2021. In comparison, 
in 2018 the levy contributed only EUR 25.7 million. Television broadcasters contributed EUR 461.1 million in 
2020 and EUR 475.4 million in 2021 (CNC, 2021; 2022).  

According to the French regulator ARCOM, between EUR 250-300 million (ARCOM, 2021) is invested annually 
in the audiovisual industry by streaming players, in addition to the above-mentioned levied contribution to the 
funding of the CNC. According to France’s most recent regulations, at least 20% of the turnover of on-demand 
players generated in France must directly finance the production of European works (5% in most European 
countries),  75%  of  which  must  be  of  original  French  expression.  On  top  of  that,  at  least  20%  of  the  total 
obligation is to be invested in cinematographic films and 75% of the contribution in cinema and two-thirds in 
audiovisual must be invested in ‘independent production’ (Articles 21 and 22 of SMAD Decree). 

Netherlands (NL) - NL Filmfonds/Dutch Film Fund 

In the Netherlands, VoD players and broadcasters do not make any contribution to the Dutch Film Fund. Under 
an agreement between the government and film exhibitors and distributors, annually VAT is kept at the rate of 
9% for film exhibition but in return EUR 0.15 of every ticket (EUR 0.09 and 0.06 for cinemas and distributors 
respectively) must contribute to the Tuschinski Fund.  

The revenues from these sources were lower in 2021 and 2020 due to COVID-19 (EUR 1 576 679 and EUR 
2  256  257  respectively).  However,  the  government  granted  an  additional  EUR  5  million  to  the  fund  to 
compensate for the shortfall. The investment in film production volume in the Netherlands rose by 41% from 
EUR 128.4 million in 2020 to EUR 180.8 million in 2021, which is higher than the pre-COVID volume of EUR 
162.7  million.  This  is  partly  the  result  of  delayed  productions  finalised  in  2021,  and  the  additional  COVID 
measures adopted by the Dutch Government (NL Filmfonds, 2022). 

Poland (PL) – Polish National Film Institute 

Poland imposed an investment obligation on VoD servicesd as part of the COVID-19 crisis relief programme, 
involving the payment of a levy to the National Film Institute for both VoD providers established in the country 
and  those  that  target  Polish  audiences  from  another  Member  State.  Broadcasters  established  in  other  EU 
countries also have an obligation to pay a levy. The legal requirements are set out in the 2020 Cinematography 
Act.  With  the  increased  uptake  of  VoD,  the  revenue  collected  has  grown.  In  the  first  quarter  of  2022,  the 
National Film Institute collected PLN7.5 million (± EUR 1.6 million), which is about PLN 577 000 (± EUR 125 
800) more than the levy revenue collected in the previous quarter and PLN2.7 million (± EUR 588 800) more 
compared with the same period the previous year.285 

285 Wirtualnemedia (n.d.), Available at: https://www.wirtualnemedia.pl/artykul/podatek-od-VoD. 

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The  levy  is  set  at  1.5%  of  the  revenue  from  fees  for  access  to  VoD  services  available  to  the  public  or  the 
revenue from broadcasting commercial communications, if this revenue in a given settlement period is higher. 
Payments to the Polish Film Institute are made quarterly. The levy for VoD providers established in another 
Member State is based on the revenues in Poland. 

4.3.3     Direct investment of video-on-demand services 

According to a data286 from the EAO based on Ampere Analysis, total investments in original European content 
increased sharply in 2021, thanks to the contribution of SVoD companies. Global streamers invested a total of 
EUR 2.8 billion in content production across the EU27 plus the UK and Norway in 2021, almost double the 
2020 total of EUR 1.5 billion. The report states that global streamers’ share of direct investments in European 
original  content287 grew  rapidly  to  16%  in  2021,  at  a  faster  pace  than  their  acquisitions.  This  arguably  led 
private  broadcasters  to  also  increase  their  investments  in  the  face  of  new  competition  and  TV  content 
standards.  

In Spain, direct investments made by global streamers accounted for 38% of all investments made in European 
original content in the market in 2021. The report also confirmed the UK’s leading position when it comes to 
content investment, with a total of EUR 5.0 million in 2021, followed by Germany with EUR 3.7 million, France 
with EUR 2.6 million, Spain with EUR 1.5 million, Italy with EUR 1.1 million, Poland with EUR 0.6 million, the 
Netherlands with EUR 0.6 million, Sweden and Belgium with EUR 0.5 million. 

According to the EAO report, in 2021, Netflix accounted for more than half of global streamers’ investments in 
Europe, down from 92% in 2019 as other streamers such as Amazon Prime Video have been investing more 
in European content. In 2021, Netflix contributed 9% of Europe’s total investment in original content, followed 
by Amazon  Prime  Video  with  4%, Disney with  2%,  and HBO Max with 1%. Disney+ commissioned  its first 
European  projects  in  France,  Italy,  Germany,  and  the  Netherlands,  as  part  of  the  EUR  15.5  billion  global 
content  spending  package  for  the  period  2022-2024. 288  The  European  slate  includes  a  mix  of  dramas, 
comedies and documentaries, with Disney+ projects targeting a family-friendly audience, while Star shows are 
aimed at a more adult audience. In 2021, at the Series Mania Lille Dialogues, Disney+ executives announced 
that the company was on track to produce 60 European original series by 2024, up from the previous target of 
50.289 In a major restructuring, HBO Max announced in 2022 it was to recalibrate its streaming priorities and 
will no longer produce originals for HBO Max in the Nordics (Denmark, Sweden, Norway and Finland), Central 
Europe, the Netherlands and Turkey.290 It will also remove some content from its platform in order to free up 
licencing deals elsewhere. Two territories that are being spared the overhaul are Spain and France, where 
originals will not be affected. European player Viaplay Group has been developing its originals catalogue with 
Nordic and international scripted  drama series, documentaries, comedies, films, animations and unscripted 
reality  shows.  At  the  end  of  2021,  there  were  152  Viaplay  Originals  available  on  the  service.  46  Viaplay 
Originals were premiered in 2021 (30 scripted and 16 documentaries), with a further 70 planned for 2022.291 

The analysis of our case studies in the section below focuses on content labelled as original/exclusive by the 
VoD  services  included,  and  particularly  US  services,  which  we  use  as  a  proxy  for  assessing  the  type  of 
investments  in  the  market.  We  distinguish  4  types:  commissions,  co-production/co-financing  deals,  or 
acquisitions  as  original/exclusive  titles.  In  order  to  align  with  the  Lumière  database  used  for  the  previous 
section, as well as with data available in the online databases used as sources and the catalogues themselves, 
the analysis focuses on the year of release and not on the year of commissioning/acquisition/production as 
this is not consistently available. However, according to other sources used by us  - such as press releases, 
company  communications  and  trade  press  -  these  titles  were  announced,  commissioned,  acquired  or  in 
production in the 2020-2021 period. However, the date of release varies, as some were already released in 

286 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe 

287 The investments are defined in the report as ‘cash investment’ in original European content, excluding acquisitions of films and 
audiovisual works, news and sport programmes. 

288 Deadline.com (2021), Available at: https://deadline.com/2021/02/disney-european-originals-star-1234693868/. 

289 Variety.com (2021), Available at: https://variety.com/2021/streaming/global/disney-plus-european-production-series-mania-
1235052634/. 

290 Variety.com (2022), Available at: https://variety.com/2022/tv/global/hbo-max-europe-originals-development-1235308730/. 

291 Viaplaygroup.com (2022), Available at: https://www.viaplaygroup.com/sites/default/files/cta/annual-report-2021.pdf. 

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2020, while others took longer in the (post-)production phase (possibly also due to COVID-19 restrictions) and 
were only released in 2022 or are still scheduled for release. 

The typology of original content is based on academic studies and uses the same methodology applied in the 
studies published by Afilipoaie et al. 2021 and Iordache et al. 2022.292 The titles were assigned to a specific 
category based on information collected from all sources indicated above with regard to content labelled as 
‘Original/exclusive’ in the markets discussed, specifically: announcements made by the companies/services 
on  their  websites  and  in  trade  press;  online  databases  (e.g.,  IMDbPro,  UNOGS.org,  www.whats-on-
netflix.com,  flixpatrol.com,  Wikipedia  etc.);  the  VoD  services  themselves  (e.g.,  (co-)production  companies 
listed  in  opening/closing  credits  of  films/series;  other  funding  bodies  mentioned  in  the  credits—such  as 
audiovisual  funds  as  indicators  of  co-financing  etc.).  Content  labelled  as  ‘acquisition’  refers  to  productions 
licenced  as  originals/exclusives  in  certain  territories,  not  to  all  content  licenced  by  the  VoDs  for  their 
catalogues.  Note  that  the  analysis  is  thus  based  on  a  categorisation  based  on  listings  of  (co)production 
partners and streamer involved, not on the actual investments or rights agreements.   

The analysis is based on: 

−  Type of investment. 

−  Country of origin. 

−  Format of content: scripted film/series, documentary film/series, animation film/series, and unscripted 
content, divided into reality film and reality/series (e.g., reality-TV formats, stand-up comedy, games 
and cooking shows). 

−  Volume by number of titles (to be/released in 2020-2023) and minutes (released in 2020-2022). The 
exact number of minutes for titles currently in production was incomplete and thus not included in the 
volume analysis. 

−  Genre – each title was manually added to one genre category out of the following eight: action/thriller, 
comedy/romance, crime, drama, family, historical drama, SciFi/fantasy/horror, teen drama/young adult 
(YA).  The  genres  were  determined  based  on  initial  labels  by  the  service  and  on  online  databases 
IMDb(Pro) and The Movie Database (TMDB). 

The labels for formats and genre are also meant to reflect a general direction for investment. For example, 
scripted  series  and  animation  are  generally  more  expensive  to  produce  than  documentary  and  unscripted 
content,  such  as  reality  films  and  series.  The  genres  were  chosen  based  on  academic  research  on  VoD 
investment  volumes  in  Europe  on  which  the  analysis  builds.293 Generally,  genres  such  as  historical  drama 
involve  higher  investments,  while  content  in  the  comedy/romance  or  family  categories  are  less  costly  to 
produce. In addition, for this report, we have created  a separate category for teen drama/young adult (YA) 
following a significant growth in this category in previous years.294 

Table 26: Number of unique VoD Originals titles 

Amazon 
Prime 

Discovery+ 

Disney+ 

HBO 
Max 

Netflix 

Paramount+ 

Salto 

Streamz 

Viaplay 

Total 

BE 

12 

1 

26 

39 

292 Afilipoaie, A., Iordache, C. and Raats, T. (2021). The ‘Netflix Original’ and what it means for the production of European television 
content. In: Critical Studies in Television 16(3), pp. 304–325. DOI: 10.1177/17496020211023318; Iordache, C., Raats, T. and Afilipoaie, 
A. (2021). Transnationalisation revisited through the Netflix Original: An analysis of investment strategies in Europe. Convergence: The 
International Journal of Research into New Media Technologies, 1-19.  

293 Afilipoaie, A., Iordache, C. and Raats, T. (2021). The ‘Netflix Original’ and what it means for the production of European television 
content. In: Critical Studies in Television 16(3), pp. 304–325. DOI: 10.1177/17496020211023318; Albornoz, LA. and Garc´ıa Leiva, MT 
(2021). Netflix originals in Spain: challenging diversity. European Journal of Communication. DOI: 0.1177/02673231211012174; 
Iordache, C., Raats, T. and Afilipoaie, A. (2021). Transnationalisation revisited through the Netflix Original: An analysis of investment 
strategies in Europe. Convergence: The International Journal of Research into New Media Technologies, 1-19; Iordache, C., Raats, T., 
and Mombaerts, S. (2022). The Netflix Original documentary, explained: global investment patterns in documentary films and series. 
Studies in Documentary Film, 1-21. 

294 Hagedoorn, B., Eichner, S., and Gutierrez Lozano, J. F. (2021). The ‘youthification’of television. Critical Studies in Television, 16(2), 
83-90; Sundet, V. S. (2021). ‘Youthification’of drama through real-time storytelling: A production study of blank and the legacy of 
SKAM. Critical Studies in Television, 16(2), 145-162. 

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CZ 

DE 

9 

FR 

IT 

21 

22 

NL 

2 

PL 

SE 

Total 

54 

9 

7 

44 

60 

1 

1 

4 

1 

7 

2 

4 

4 

1 

11 

2 

1 

8 

4 

50 

55 

53 

15 

52 

18 

255 

11 

5 

26 

1 

65 

85 

97 

25 

59 

90 

461 

2 

3 

27 

32 

The dataset for the case studies of the eight EU countries consists of 461 unique VoD Originals titles, 295 
acquired (as exclusives), co-produced/co-financed, or commissioned by six US VoD services: Netflix, Amazon 
Prime  Video,  Disney+,  HBO  Max,  Discovery+,  and  Paramount+,  two  domestic  services:  Salto  (FR)  and 
Streamz (BE) and the pan-European service Viaplay (SE). Content that was commissioned or co-produced by 
other  services/companies  prior  to  being  acquired  by  a  VoD  service  as  original/exclusive  is  listed  as  an 
acquisition in the majority producing country. 

Figure 2423: Volume of EU8 VOD Originals in minutes released in 2020-2022 

2
2
0
2

1
2
0
2

0
2
0
2

Commission
Co-production/co-financing
Acquisition
Commission
Co-production/co-financing
Acquisition
Commission
Co-production/co-financing
Acquisition

0

10000

20000

Amazon Prime

Discovery+

Disney+

HBO Max

Netflix

Paramount+

Salto

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Out  of  the  total  461  titles,  262  were  commissions,  119  acquisitions  (as  exclusives,  labelled  as 
Originals/Exclusive), and 80 were co-production/co-financing deals. 

The categories of content used are based on an extensive academic literature review and previous empirical 
studies conducted by the research team. Although individual cases may differ, we use this mapping as a proxy 
for investment volumes by titles and types of investment. However, there are limitations to the results, as the 
mapings  do  not  include  information  on  actual  production  budgets,  investment  weight  in  the  case  of  co-
production/co-financing  deals,  or  data  regarding  the  length  of  specific  deals  (e.g.,  in  the  case  of  licensed 
originals/exclusives). According to these sources, the agreements have the following general characteristics.  

For  the  type  we  labelled  as  ‘commissions’,  the  streaming  platform  is  involved  in  the  production,  either  as 
commissioner (in which the streamer collaborates with a production company) and/or as a producer itself (for 
example in production hubs, such as the ones in Spain and the United Kingdom).296 The type of productions 
we  labelled  as  ‘acquisitions’  are  those  productions  where  the  streaming  platform  picked  up  the  series  for 
distribution after production. The streaming service in this case is not labelled as a production partner in listings 
such  as  imdbpro.Co-production  and  co-financing  deals  are  discussed  together  as  it  is  difficult  to  make  a 

295 In the case study analyses below some titles are listed both for the majority and the minority production country/ies, if listed as an 
original by a VoD service active in the country. 

296 Variety.com (2022), Available at: https://variety.com/2022/film/festivals/netflix-vis-amazon-disney-hbo-max-1235359890/. 

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distinction between them, as data on budgets, rights, revenues and editorial control over the production are all 
needed in order to determine the exact typology.  

Figure 24: Type of investment in number of titles (EU8) by VoD service 

Commission

Co-production/co-financing

Acquisition

Amazon Prime

Discovery+

Disney+

HBO Max

Netflix

Paramount+

Salto

Streamz

Viaplay

0

50 100 150 200 250 300

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Table 27: Total number of titles by format (columns) and genre (rows). 

animation 
film 

animation 
series 

documenta
ry film 

documenta
ry series 

film 

reality film 

reality 
series 

series 

Total 

Action/Thriller 

Comedy/ 
Romance 

Crime 

1 

Documentary 

22 

36 

Drama 

Family 

Historical drama 

Reality/Stand-up 

SciFi/Fantasy/Hor
ror 

Teen drama/YA 

1 

2 

1 

4 

28 

33 

8 

1 

31 

8 

3 

16 

9 

15 

48 

43 

37 

2 

7 

20 

26 

43 

82 

51 

59 

68 

13 

10 

63 

37 

35 

9 

54 

Total 

1 

22 

36 

137 

9 

54 

198 

461 

The most popular formats for the investments in originals are scripted series, film, and reality series. The most 
common genres are comedy/romance, drama, reality/stand-up and documentary.  

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Figure 25: Genres and formats for VoD Original titles in EU8. 

Teen drama/YA

SciFi/Fantasy/Horror

Reality/Stand-up

Historical drama

Family

Drama

Documentary

Crime

Comedy/Romance

Action/Thriller

animation film

animation series

documentary film

documentary series

film

reality film

reality series

series

0

20

40

60

80

100

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Belgium (BE) 

The EAO reported that in 2021 the share of global streamers in total investments in Belgium was 12% of total 
European content investment, and the market share of global streamers’ investments was slightly less than 
that of broadcasters’ investments in the market, at approximately 2%.297 Foreign services Netflix and Amazon 
Prime Video have been available in Belgium since 2015 and 2016, respectively, and were joined by Disney+ 
in 2020. In that time, Netflix acquired licence deals for Tabula Rasa (2017–) and Hotel Beau Séjour (2016–), 
which were streamed as Netflix Originals outside of Belgium. It continued with the co-financing/co-production 
deal for Undercover (2019–), and in 2019 invested in its first commissioned original, SciFi series Into the Night 
(2020–), which was renewed for a second season release in 2021. Amazon Prime Video acquired minority 
Belgian co-production De Oost (2020) as exclusive on streaming. Disney+ has not yet announced any Belgian 
original productions. 

Domestic SVoD Streamz has also been investing in VoD original productions in  the Dutch-speaking part of 
Belgium.  The  service  was  launched  as  a  joint  venture  between  Flemish  companies  Telenet  (which  owns 
broadcaster SBS) and DPG (which owns broadcaster VTM) in order to add a new tier of revenue, but also to 
ensure the ongoing viability of the funding of scripted television. The Streamz model that was set up consists 
of co-productions between the SVoD service and one of the two commercial broadcasters, where Streamz 
obtains a premium window and exclusivity for a certain period of time, after which the series are released on 
television. Streamz originals include some scripted series, entirely exclusive to the service, usually low-budget 
or  short-format  comedy  series  aimed  at  younger  audiences.  Recently,  the  service  has  been  expanding  its 
originals  to  documentary  and  human-interest  programming,  which  are  more  affordable  for  the  service  to 
produce. The streamer has also become less dependent for its commissions on broadcasters, as they aim for 
more exclusive content.298 

A total of 43 titles were produced as the result of direct investments by VoD services in Belgium in the period 
2020-2022: 26 by Streamz, 16 by Netflix, one by Amazon Prime Video, and one by Salto. Five of the Netflix 

297 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe 

298 Information on Streamz based on the following sources: Raats, T., and Evens, T. (2021). ‘If you can’t beat them, be them’: A critical 
analysis of local streaming platform and Netflix alternative Streamz. MedieKultur: Journal of media and communication research, 37(70), 
050-065; Vlaamse Regulator voor de Media (2022). Mediaconcentratie in Vlaanderen [Media concentration in Flanders]. Brussels: VRM, 
Available at: https://www.vlaamseregulatormedia.be/nl/mediaconcentratie; Serrure B (2023). ‘De kijker moet heropgevoed worden’. Tijd. 
Available at: https://www.tijd.be/ondernemen/media-marketing/bart-de-groote-ceo-streamz-de-kijker-moet-heropgevoed-
worden/10443053.html; Vlaamse Audiovisueel Fonds (2023). 2022 Jaarverslag. Available at: 
https://www.vaf.be/files/Jaarverslagen/VAF-jaarverslag-2022.pdf.  

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Originals (three acquisitions and twoco-production/co-financing deals) have Belgium as minority producer, four 
with France and one with Luxembourg. 

Figure 26: Titles with release in 2020-2023 as VoD originals in Belgium. 

14

12

10

8

6

4

2

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Co-production/co-financing

Acquisition

2020

2021

2022

2022/2023

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

A total of 9 513 minutes were released in 2020-2022: 2 596 minutes in 2020, 2 881 in 2021, and 4 063 in 2022. 
Co-production/co-financing  deals  consisted  of  4,616  minutes,  followed  by  acquisitions  (3  495  min)  and 
commissions (1 402 min). Belgium is one of the top minority producing countries in Europe, with an established 
record of co-production/co-financing deals with larger media markets, particularly France, but also Germany 
and the Netherlands. 

Figure 27: Volume of investment in original content by VoD and type of investment in 2020-2022 

3500
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1500
1000
500
0

e
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Acquisition

x

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2020

2021

2022

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

In terms of format, the majority (31 titles) are scripted series, ten are films, and there is one documentary series 
and one documentary film. 

Figure 28: Number of original productions by format and VoD. 

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series

film

documentary series

documentary film

Amazon Prime

Netflix

Streamz

0

10

20

30

40

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The most common genre is comedy/romance (13 titles), followed by action/thriller (8 titles), crime (6 titles), and 
SciFi/fantasy/horror (5 titles).  In volume of minutes released in 2020-2022, comedy/romance totalled 3 484 
minutes, followed by crime (1 837 min), action/thriller (1 310) and drama (1 149 min). 

Figure 29: Volume in minutes released in 2020-2022 per genre and VoD 

4000

3500

3000

2500

2000

1500

1000

500

0

Streamz

Netflix

Amazon Prime

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Czechia (CZ) 

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Czechia is a small European market that has received limited attention from foreign VoD investment. Netflix 
and Amazon Prime video are the key foreign SVoD players, with HBO Max and Disney+ having launched in 
the Czech market in 2022. A total of seven titles were produced as the result of direct investments by foreign 
VoD  services  in  the  period  2020-2022.  Of  these,  only  one  was  a  full  Czech  commission:  the  HBO  Max 
documentary series Czech It Out! (2022). For the remaining six titles Czechia was minority co-producer299. 
Netflix released three films and two series, and Amazon Prime Video one series. 

Figure 30: Titles with release in 2020-2023 as VoD originals in Czechia 

3

2.5

2

1.5

1

0.5

0

Commission

Co-production/co-financing

Acquisition

Netflix

Amazon
Prime

Netflix

HBO Max

Netflix

2020

2021

2022

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The  productions  released  in  2020-2022  had  a  total  volume  of  1  570  minutes,  with  Netflix  leading  with  906 
minutes, followed by Amazon Prime Video (480 min) and HBO Max (184 min). 

299 The minority co-producer is any country of origin other than the first country of origin (which is associated with the majority producer), 
based on the data used for the study (production companies in credits, IMDBPro, Lumiere database, trade press etc.) 

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Figure 31: Volume of investment in original content by VoD and type of investment in 2020-2022. 

600

500

400

300

200

100

0

Commission

Co-production/co-
financing

Acquisition

Netflix Amazon

Netflix HBO Max Netflix

Prime

2020

2021

2022

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press. 

In terms of genre, there were two historical dramas, two SciFi/fantasy/horror productions, and one of each of 
the following: action/thriller, documentary, teen drama/YA. But, in volume, the Amazon Prime teen drama/YA 
minority co-production (DE-IT-CZ) We Children from Bahnhof Zoo (2021) totalled 480 minutes, followed by 
two  SciFi/fantasy/horror  Netflix  co-production/co-financing  deals  (total  405  min):  the  2021  series  Tribes  of 
Europa (DE-CZ-HR) and 2022 film Blood Red Sky (DE-CZ). 

Figure 32: Volume in minutes per genre and VoD. 

600
500
400
300
200
100
0

Netflix

HBO Max

Amazon Prime

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

France (FR) 

The EAO reported that in 2021 the share of global streamers in total investments in France was 12% of the 
total European content investment, and the market share of global streamers’ investments was approximately 
11%, less than that of broadcasters’ investments in the market which represented 15%.300 In December 2021, 
streamers Netflix, Amazon, Disney+ and Apple TV+ struck a long-anticipated deal with the French radio and 

300 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe 

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television regulator CSA that could see the group invest EUR 250-300 million a year on average in French 
programming.301 The deal could raise between EUR 150-200 million annually from Netflix alone.302 

Netflix is the largest contributor of foreign VoD investment. The streamer launched in France in 2014, which 
has  become  an  essential  market  both  for  subscribers  and  content  acquisition  and  commissioning  for  the 
company. In January 2020, Netflix opened a new Paris office and announced it was increasing its investment 
in France.303 In 2022 Netflix also signed a three-year agreement with French film guilds to invest a minimum 
of  EUR  40  million  in  the  financing  of  French  and  European  films,  with  at  least  EUR  30  million  invested  in 
French-language films. The agreement also  has a  provision for  lower  budget  films and  features a  diversity 
clause under which Netflix will have to allocate at least 17% of the EUR 40 million to financing French-language 
movies with a budget of under EUR 4 million. The streamer will need to invest in a minimum of ten films at the 
pre-financing stage.304  

In an attempt to counter the foreign VoD dominance, private channels TF1 and M6, and public broadcaster 
France Televisions launched their SVoD service Salto in October 2020. The three-party joint venture had to 
clear several hurdles, including negotiating a complex partnership agreement, getting anti-trust approval, and 
the delays resulting from the pandemic. However, according to a survey carried out by CNC in January 2022, 
the service was underperforming with only about 500 000 paying subscribers at the beginning of the year.305 
Salto also started to (co-)produce its own original content in 2021, but the majority of its exclusive/first-window 
offerings are investments made by the broadcasters involved. 

A total of 87 titles were produced as the result of direct investments by VoD services in France in the period 
2020-2022: 56 Netflix Originals, 22 Amazon Prime originals, four Disney+ originals, four Salto originals, and 
one Paramount+ production. 

Figure 33: Titles with release in 2020-2023 as VoD originals in France. 

30
25
20
15
10
5
0

x

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2021

2022

2022/2023

Commission

Co-production/co-financing

Acquisition

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

In total 15 202 minutes were released in 2020-2022: 3 512 minutes in 2020, 6 235 in 2021 and 5 455 in 2022. 
Commissions  accounted  for  9  628  minutes  released  in  this  period,  acquisitions  for  3  126  minutes  and  co-
production/co-financing deals for 2 448 minutes. 

301 Variety.com (2021), Available at: https://variety.com/2021/film/global/netflix-amazon-disney-plus-apple-tv-plus-avms-france-
1235130056/. 

302 Forbes (2021), Available at: https://www.forbes.com/sites/chrisobrien/2021/01/11/salto-enters-streaming-wars-to-reinvent-and-save-
french-television/. 

303 Netflix (n.d.), Available at: https://about.netflix.com/en/news/netflix-opens-new-paris-office-and-increases-investment-in-france. 

304 Variety.com (2022), Available at: https://variety.com/2022/film/global/netflix-investment-french-movies-1235187142/. 

305 Capital.fr (n.d.), Available at: https://www.capital.fr/entreprises-marches/les-vrais-chiffres-de-salto-1426842. 

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Figure 34: Volume of investment in original content by year of release, VoD and type of investment. 

4500
4000
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3000
2500
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1500
1000
500
0

Commission

Co-production/co-financing

Acquisition

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2020

2021

2022

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The majority of productions were films (30), followed by scripted series (26), ten documentary series, eight 
documentary films, seven reality series, three reality films, two animation series and one animation film. 

Figure 3635: Number of original productions by format and VoD 

series

reality series

reality film

film

documentary series

documentary film

animation series

animation film

Amazon Prime

Disney+

Netflix

Paramount+

Salto

0

5

10

15

20

25

30

35

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Netflix released a total of 56 French originals: 16 in 2020, 26 in 2021 and 14 in 2022. The majority represented 
scripted content (22 films and 16 series), followed by eight documentary films. 33 of the 56 Netflix Originals 
were commissions, 15 acquisitions and  eight co-production/co-financing deals,  with France as minority co-
producer in two films and one animation series. 

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Figure 36: Netflix Originals in France by type of investment and format. 

2
2
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animation film

animation series

documentary film

documentary series

film

reality film

reality series

series

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

0

5

10

15

20

Amazon  Prime  Video  released  a  total  of  22  French  originals:  six  in  2020,  11  in  2021  and  five  in  2022, 
consisting of eight films, six documentary series, four reality series, three scripted series and one reality film. 
Thirteen  of  the  total  were  commissions,  seven  acquisitions,  and  two  co-production/co-financing  deals,  with 
France as minority producer in one film. 

Figure 37: Amazon Prime Video originals in France by type of investment and format. 

Commission

Acquisition

Co-production/co-
financing

documentary series

film

reality film

reality series

series

0

5

10

15

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

With regard to genre, the majority of titles (to be) released in 2020-2023 are documentaries (18), followed by 
16 comedy/drama, 13 action/thrillers, ten reality/stand-up, eight crime titles, seven Sci-Fi/fantasy/horror, five 
dramas, four teen drama/YA, three historical dramas and three productions in the family category. The volume 
of content released in 2020-2022 maintains the same hierarchy, the top five genres being documentary (2 485 

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min), comedy/romance (2 416 min), action/thriller (2 166 min), reality/stand-up (1 813 min), and crime (1 652 
min). 

Figure 38: Volume in minutes released in 2020-2022 per genre and VoD. 

3000

2500

2000

1500

1000

500

0

Salto

Netflix

Disney+

Amazon Prime

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Germany (DE) 

The EAO reported that in 2021, the share of global streamers in total investments in Germany was 8% of the 
total European content investment, and the market share of global streamers investments was less than half 
that of broadcaster investments in the market, at approximately 11%.306 In February 2022, Netflix unveiled a 
slate of new German-language original programming for the Germany/Austria/Switzerland region, a push into 
German-language content claiming to double the company’s investments to EUR 500 million between 2021 
and 2023.307 

A total of 71 titles were found as the result of direct investments made by foreign VoD services in Germany, 
released between 2020-2023. There are 53 Netflix Originals produced/commissioned in 2020-2021, and 10 
Amazon Prime Video originals/exclusives. Viaplay is planning to launch in Germany in 2023 but it has already 
been  involved  in  4  co-productions  with  Germany  as  majority  producer  in  2  series  from  2021  and  1  that  is 
scheduled  for  2022/2023,  and  as  minority  producer  in  2  series  from  2021  and  2022.  Disney+  entered  the 
German market in 2020 and commissioned its first 2 Disney+ Originals in 2021, to be released in 2022/2023: 
the drama series Sam – A Saxon and the crime series Sultan City. 

Figure 39: Titles with release in 2020-2023 as VoD originals in Germany. 

306 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe 

307 Hollywoodreporter.com (n.d.), Available at: https://www.hollywoodreporter.com/business/business-news/netflix-unveils-new-german-
language-original-series-and-films-1235088713/. 

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25

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

In total, 11 664 minutes were released in 2020-2022: 8 854 by Netflix, 1 948 by Amazon Prime, and 862 by 
Viaplay. Of these, commissions accounted for 5 521 total minutes released in this period, co-production/co-
financing deals 3 559 minutes, and acquisitions 2 584 minutes. 

Figure 40: Volume of investment in original content by year of release, VoD and type of investment. 

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2022

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Of the 71 titles, 31 were scripted series and 21 films, seven were documentary series, five were reality series, 
four were documentary series and three were documentary films. 

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Figure 41: Number of original productions by format and VoD. 

series

reality series

reality film

film

documentary series

documentary film

Amazon Prime

Disney+

Netflix

Paramount+

Viaplay

0

10

20

30

40

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Netflix released 18 originals in 2020, 23 originals in 2021, and 12 in 2022. The productions were fairly diverse 
in terms of format, but the majority were scripted titles (20 films and 18 series). 29 of the 53 Netflix Originals 
were commissions, 15 were acquisitions and nine were co-production/co-financing deals, with Germany as 
minority co-producer in one documentary series. 

Figure 42: Netflix Originals in Germany by type of investment and format. 

2
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documentary film

documentary series

film

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reality series

series

0

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15

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The genres are also very diverse. Titles (to be) released in 2020-2023 consist of 11 documentary 
productions,  ten  dramas,  eight  titles  in  each  of  the  categories  of  action/thriller,  comedy/romance, 
reality/stand-up,  SciFi/fantasy/horror,  teen  drama/YA,  six  crime  productions  and  five  historical 
dramas. The figure below shows the volume in minutes for titles already released in 2020-2022. 

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Figure 43: Volume in minutes released in 2020-2022 per genre and VoD. 

1800
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1400
1200
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Viaplay

Netflix

Amazon Prime

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Italy (IT) 

Netflix, Amazon Prime Video, Disney+, and HBO Max are all active on the Italian market. Netflix Italia’s Director 
of Institutional Relations stated that from 2017 to 2020, Netflix invested EUR 300 million in the Italian market 
to produce over 45 shows.308 According to APA, the local TV producers association, in 2022 the Italian market 
was expected to generate more than EUR 1.2 billion worth of scripted content, resulting in double-digit growth. 
Netflix, Amazon and Disney spent a combined total of roughly EUR 147 million on Italian scripted content in 
2021, and they are expected to almost double their investments in Italian originals to at least EUR 282 million 
by  2023,  becoming  Italy’s  main  TV  industry  drivers,  according  to  APA  chief  Giancarlo  Leone.309 The  EAO 
reported that in 2021 the share of global streamers in total investments in Italy was 16% of the total European 
content  investment,  and  the  market  share  of  the  investments  of  global  streamers  was  equal  to  that  of 
broadcasters, at approximately 6-7%.310 

Paramount+  also  entered  the  market  in  September  2022,  with  several  commissions,  co-productions,  and 
acquisitions  already  in  the  pipeline  since  2021.  Discovery+  entered  the  market  as  a  streaming  service 
alongside the existing Discovery digital terrestrial channels: Discovery Channel, Real Time, DMAX, and Nove 
and the Sky package (e.g., Discovery Channels and Eurosport).  

A total of 98 titles were produced as the result of direct investments by these foreign VoD services: 53 Netflix 
Originals, 23 Amazon Prime Video productions, nine Discovery+ Originals, eight Paramount+, four Disney+, 
and one original for HBO Max. 

Figure 44: Titles with release in 2020-2023 as VoD originals in Italy. 

308 Euronews.com (2022), Available at: https://www.euronews.com/culture/2022/04/01/how-european-countries-are-taxing-netflix-to-
invest-in-cinema. 

309 Variety.com (2022), Available at: https://variety.com/2022/tv/spotlight/my-brilliant-friend-italian-tv-1235220399/. 

310 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe 

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2020

2021

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2022/2023

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press. 

In total, 15 923 minutes were released in 2020-2022: 8 089 minutes for Netflix, 4 012 minutes for Amazon 
Prime Video, 1  900 minutes for Discovery+, 955 minutes for Disney+, 550  minutes for HBO Max, and 417 
minutes  for  Paramount+.  Commissions  accounted  for  a  total  of  8  372  minutes  released  in  this  period, 
acquisitions for 5 294 minutes and co-production/co-financing deals for 2 257 minutes. 

Figure 45: Volume of investment in original content by year of release, VoD and type of investment. 

4000

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2020

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Of  the  98  productions,  37  were  scripted  series,  33  films,  12  reality  series,  nine  documentary  series,  five 
documentary films, one animations series and one reality film. 

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Figure 46: Number of original productions by format and VoD. 

series

reality series

reality film

film

documentary series

documentary film

animation series

Amazon Prime

Disney+

HBO Max

Netflix

Paramount+

Discovery+

0

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25

30

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The majority of Netflix and Amazon Prime Video originals are commissions. Co-production/co-financing deals 
include the Prime Video minority co-production We Children from Bahnhof Zoo (2021) and the IT-UK-IE Netflix 
fantasy series Fate: The Winx Saga (2021-2022), and IT-UK Netflix documentary series Vendetta: Truth, Lies 
and The Mafia (2021).  

Figure 47: Titles released by Netflix and Amazon Prime Video as originals in Italy by type of investment. 

2022/2023

2022

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2022/2023

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

With regard to genre, comedy/romance and drama have 20 titles each, documentary 15 titles, 13 reality-stand-
up shows, eight teen drama/YA, seven Sci-Fi/fantasy/horror, six crime titles, four action/thrillers, three family 
productions and two historical dramas. In volume of minutes released in 2020-2022, comedy/romance titles 
totalled  2  844  minutes,  reality/stand-up  2  780  minutes,  followed  by  drama  with  2  530  minutes,  and 
documentary with 1 841 minutes. 

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Figure 48: Volume in minutes per genre and VoD released in 2020-2022. 

3000

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Discovery+

Paramount+

Netflix

HBO Max

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The Netherlands (NL) 

The EAO reported that in 2021 the share of global streamers in total investments in the Netherlands was 23% 
of the total European content investment, and the market share of global streamers’ investments was slightly 
higher than that of broadcasters’ investments in the market, at just under 5%.311 

A total of 26 titles were produced as the result of direct investments by foreign VoD services in the Netherlands 
in the period 2020-2022: 16 Netflix Originals, seven Discovery+, two Amazon Prime Video and one Disney+.  

Figure 49: Titles with release in 2020-2023 as VoD originals in the Netherlands. 

12

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, 
The Movie Database, the VoD catalogues, academic literature and trade press 

311 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe 

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The volume in minutes for the content released in 2020-2022 totalled 4 199 minutes. Netflix released the most 
(1 918 min), followed by Discovery+ (1 601 min), Disney+ (540 min), and Amazon Prime (140 min). 

Figure  50:  Volume  of  investment  in  original  content  released  in  2020-2022  by  VoD  and  type  of 
investment. 

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2020

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Of  the  26  productions,  12  were  films,  five  were  reality  series,  four  were  scripted  series,  followed  by 
documentary series (3) and films (2). 

Figure 51: Number of original productions by format and VoD. 

series

reality series

film

documentary series

documentary film

Amazon Prime

Disney+

Netflix

Discovery+

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, 
The Movie Database, the VoD catalogues, academic literature and trade press 

0

5

10

15

Netflix  released  its  first  full  Dutch  original  series  in  2020,  followed  by  ten  more  original  titles  in  2021:  two 
documentary  films,  seven  feature  films  and  two  series,  and  four  titles  in  2022:  three  films  and  one  series. 

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Commissions in the market are still limited, one in 2020, three in 2021 and one in 2022. Most titles continue to 
be acquired as licenced exclusives (in some markets): six in 2021 and three in 2022. Two co-production/co-
financing deals were released in 2021, including the BE-NL crime film Ferry for which the Netherlands was the 
minority producer. The Netflix titles accounted for a total of 1 918 minutes released in 2020-2022: 240 minutes 
in 2020, 1 144 in 2021 and 534 in 2022. Acquisitions consisted of a total of 930 minutes released in this period, 
commissions 786 minutes and co-production/co-financing deals 202 minutes. 

Figure 52: Netflix Originals in the Netherlands by year of release, format and type of investment. 

2
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7

In  January  2021,  Discovery  Inc.’s  VoD  service  dplay  was  replaced  by  Discovery+  in  European  markets 
including the Netherlands. The company set up a major technology hub in the Netherlands in 2020312 and has 
also invested in European works and sports programming. A total of four Dutch Discovery+ Originals were 
commissioned  in  2021:  one  documentary  series  (188  min),  one  stand-up  show  and  two  reality  series  (903 
min); and two in 2022: one reality series (240 min) and one true crime documentary series (270 min). One 
stand-up series in yet to be released in 2022/2023. 

In 2020, Amazon Prime Video acquired the international historical drama co-production De Oost (NL, BE, ID, 
US, FR; 140 min) and commissioned a romantic comedy based on its drama format  Modern Love, entitled 
Modern Love Amsterdam, scheduled for release in the winter of 2022. 

Disney+ released its first Dutch commissioned programme in 2021: the documentary series That One Word 
– Feyenoord (540 min). Disney+ commissioned its first original fiction series in the Netherlands in 2022. The 
eight-part crime series Nemesis is scheduled for release in the autumn of 2023 and will be produced by the 
production  company  Pupkin313,  which  was  also  commissioned  for  Netflix’s  first  original  Dutch  series  Ares 
(2020). 

Viaplay launched in the Netherlands in 2022 when it also announced its first two scripted Dutch original series, 
to be released in 2023.314 

With regard to genre, documentary and reality-stand-up are the most common (five titles each), followed by 
drama and comedy/romance (four titles). In volume of minutes released in 2020-2022, documentary accounted 
for 1,147 minutes released, and reality/stand-up productions 1,143 minutes. It is worth noting that reality TV 
series are a popular choice with Dutch audiences and, together with documentary, also cheaper genres to 
produce  than  scripted  fiction  content.  They  were  followed  in  volume  by  drama  with  555  minutes, 
SciFi/fantasy/horror with 325 minutes, comedy/romance with 283 minutes, teen drama/YA (282 min), crime 
(107 min), and action/thriller (90 min). 

312 Investinholland.com (n.d.), Available at: https://investinholland.com/news/discovery-opens-major-technology-hub-in-the-netherlands/. 

313 Variety.com (2022), Available at: https://variety.com/2022/tv/global/disney-plus-dutch-nemesis-1235195017/. 

314 Cineuropa.org (n.d.), Available at: https://cineuropa.org/newsdetail/422475/. 

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Figure 53: Volume in minutes per genre and VoD. 

1400

1200

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0

Discovery+

Netflix

Disney+

Amazon Prime

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

For the 16 Netflix Originals, four titles were dramas, three fell in the category of comedy/romance, two were 
documentaries, two were SciFi/fantasy/horror, two were teen drama/YA, one was action/thriller, one was crime, 
and one was historical drama. In total volume of minutes released in 2020-2022, the drama genre accounted 
for  555  minutes  released,  followed  by  SciFi/fantasy/horror  (325  min),  comedy/romance  (283  min),  teen 
drama/YA (282 min), documentary (149 min), historical drama (127 min), crime (107 min), and action/thriller 
(90 min).  

Figure  54:  Volume  in  total  minutes  of  Dutch  Netflix  Originals  released  in  2020-2022  by  genre  and 
format. 

600
500
400
300
200
100
0

series

documentary film

film

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Poland (PL) 

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Poland is an attractive market for streaming services, as it is the largest and richest country in the CEE, with 
a strong film and TV production industry and significant potential for subscriber growth. In recent years, direct 
investment in Polish original series has grown significantly, leading to releases by both local (Player.pl) and 
foreign  players  (AXN,  Canal+,  Netflix,  HBO,  Viaplay).  The  crime  genre  has  been  particularly  popular  with 
previous local series, such as AXN’s The Crime (2014-2015) and Ultraviolet (2017; picked up by Netflix as a 
continuation deal  in  2019), and  HBO’s  Blinded  by the Lights (2018)  and The Pack/The Border  (2014). The 
EAO reported that in 2021 the share of global streamers in total investments in Poland was 14% of the total 
European content investment, and the market share of global streamers’ investments was nearly as large as 
that of broadcasters’ investments in Poland, between 3-5%.315 

Netflix  announced  the  opening  of  a  new  office  in  Warsaw,  in  late  2022,  that  will  serve  as  a  hub  for  the 
streamer’s  operations  across  Central  and  Eastern  Europe  (CEE).  On  this  occasion,  the  company  reported 
having invested over EUR 105 million in local original films and series since 2016.316 

A total of 60 titles were produced as the result of direct investments by foreign VoD services in Poland in the 
period 2020-2022: 53 Netflix Originals, four HBO Max Originals and three Viaplay Originals. 

Figure 55: Titles with release in 2020-2023 as VoD originals in the Netherlands. 

18
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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The total volume in minutes was 6 576 minutes for the content released in 2020-2022: 6 182 for Netflix and 
394 for HBO Max. 

315 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe. 

316 Netflix.com (n.d.), Available at: https://about.netflix.com/en/news/netflix-bets-on-central-and-eastern-europe. 

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 Figure 56: Volume of investment in original content by VoD and type of investment in 2020-2022 

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Netflix

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

Of the 53 Netflix Originals in 2020, Netflix released one original series and five films. In 2021, the streamer 
released three original Polish series, 11 original films, and one animation series. In 2022, Netflix released six 
original Polish series and ten original films. In addition, Poland was also the minority co-producer in the DE-
PL Netflix crime film The perfumier (2022). 

Figure 57: Netflix Originals in Poland by format and type of investment. 

series

film

animation series

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The number of Netflix commissioned titles grew from two in 2020 and three in 2021 to reach eight in 2022, 
while  15  are still to be released  in the coming  months. Licenced titles (acquisitions) consisted of four titles 
released  in  2020,  nine titles in  2021 and five titles  in  2022. The  Polish Film Institute (Polski Instytut Sztuki 
Filmowej) was involved in (nearly) all the co-production/co-financing titles released by Netflix, which consisted 
of three titles in 2021, four in 2022 (of which, Poland was minority co-producer for one film), and one still to be 
released. The formats consist of one animation series, 34 films, and 18 fiction series. The titles totalled 6 182 
minutes released in 2020-2022: 902 minutes in 2020, 2 278 minutes in 2021 and 3 002 minutes in 2022. No 
data is available for content yet to be released in 2022/2023. Co-production/co-financing consisted of 1 202 
total minutes released, acquisitions 2 223, while commissions accounted for the largest volume with 2 757 
minutes. 

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 Figure 58: Volume of content realised as Polish Netflix Originals in 2020-2022. 

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1000 1500 2000 2500 3000

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

In terms of genre, 16 titles were in the drama category and one in the historical drama category, followed by 
nine titles labelled as comedy/romance, eight as crime, six as action/thriller, five as SciFi/fantasy/horror, four 
as teen drama/YA and three as family. 

 Figure 59: Genres for Netflix Original releases in Poland by type of investment per year. 

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

However,  in  total  volume  of  minutes  released  in  2020-2022,  the  crime  genre  was  the  largest  (1  558  min), 
followed by comedy/romance (1 289 min), drama (1 244 min), SciFi/fantasy/horror (706 min), family (550 min), 
action/thriller (419), teen drama/YA (323 min), and historical drama (93). 

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 Figure 60: Volume in total minutes of Polish Netflix Originals by genre and format in 2020-2022. 

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400
200
0

animation series

series

film

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

HBO Max entered the Polish market as an SVoD service in March 2022 and a month later it launched The 
Thaw, a UK-Poland co-production crime mini-series with the contribution of the Polish Film Institute. However, 
the  first  HBO  Max  Originals  was  a  documentary  film  Film  Balkonowy,  a  co-production/co-financing  deal 
released  in  2021  with public support. The two productions  accounted  for 394 total  minutes released. Teen 
series Trauma, commissioned in 2021, is yet to be released in 2022/2023. Due to the work on combining HBO 
Max and discovery+ into one global streaming service (because of the Warner Bros. Discovery merger), the 
company  reviewed  their  commissioning  strategy  in  2022,  deciding  to  remove  a  limited  amount  of  original 
programming from HBO Max, and cease HBO Max direct investments in the Nordics and Central Europe.317 
It has been reported that WBD will continue to invest in local commissions and acquisitions in Europe, but that 
original programming responsibilities will now be handled by the company’s local linear and streaming teams, 
and  there  will  be  no  commissions  purely  for  streaming.318  This  is  currently  affecting  the  second  HBO  Max 
Polish  original  series  Warszawianka  (commissioned  in  2020),  as  filmmakers  cooperating  with  the  platform 
have been informed that HBO is considering cancelling or selling projects to other entities. Some creators who 
were in the early stages of production received an offer to recover their copyrights, which would allow them to 
continue working with another producer.319 

Viaplay Group entered the Polish market in 2021 when it announced that its first scripted Viaplay Originals in 
Poland, three drama series, were entering development: one crime series, an action/thriller, and a drama.320 
The three are expected to be released in 2022/2023. 

Amazon Prime Video and Disney+ have not yet commissioned any original content in Poland.  

Sweden (SE) 

The European Audiovisual Observatory reported that in 2021 the share of global streamers in total investments 
in  Sweden  was  16%  of  the  total  European  content  investment,  and  the  market  share  of  global  streamers’ 

317 Variety.com (2022), Available at: https://variety.com/2022/tv/global/hbo-max-europe-originals-development-1235308730/. 

318 Deadline.com (2022), Available at: https://deadline.com/2022/08/hbo-max-europe-29-to-depart-1235099996/. 

319 Teleshw.wp.pl (n.d.), Available at: https://teleshow.wp.pl/czarne-chmury-nad-hbo-max-w-polsce-serial-z-borysem-szycem-nie-trafi-
na-platforme-6805528699271904a. 

320 Viaplaygroup.com (n.d.), Available at: https://www.viaplaygroup.com/news/news-releases/nent-group-announces-first-polish-viaplay-
originals. 

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investments was equal to that of broadcasters’ investments in the market, at approximately 3%.321 The most 
prominent foreign SVoD players in the Swedish market are Netflix, Discovery+, HBO Max, and Disney+. The 
majority  of  original  titles  in  Sweden  were  produced  by  Netflix  and  Discovery+,  alongside  Swedish  service 
Viaplay.  

A total of 90 titles were produced as the result of direct investments by these VoD services in the period 2020-
2022: 44 productions by Discovery+, 27 productions by Viaplay, 18 titles by Netflix, and one by HBO Max. The 
analysis includes all titles labelled as Discovery+ Originals, part of which have also been co-commissioned/co-
financed with Kanal 5, the linear channel of Discovery in Sweden, which often broadcasts the content after its 
launch on the streaming service. There are several HBO Nordic Originals in the market but only one title has 
been promoted and labelled as HBO Max Original, the comedy/romance series Lust (2022). 

Figure 61: Titles with release in 2020-2023 as VoD originals in Sweden. 

30
25
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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The titles accounted for a total of 22 234 minutes released in 2020-2022: Discovery+ with 11 860 minutes, 
Viaplay with 6 212 minutes, Netflix with 3 946 minutes, and HBO Max with 216. Commissions consisted of 16 
216 minutes released in this period, co-production/co-financing deals 4 281 minutes and acquisitions 1 734 
minutes. 

321 Council of Europe (2022). Investments in original European content - A 2011-2021 analysis. Brussels: coe. Available at: 
https://rm.coe.int/investments-in-european-original-content-2011-2021-analysis-september-
/1680a75db4&sa=D&source=docs&ust=1668493064781519&usg=AOvVaw1svJ9iB2zNADxnJG6pnjSe. 

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Figure 62: Volume of investment in original content by VoD and type of investment in 2020-2022. 

8000

7000

6000

5000

4000

3000

2000

1000

0

x

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Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

With regard to format, 48 of the 90 productions were scripted series, 25 were reality series, eight were films, 
six  were  documentary  series,  two  were  reality  films  (stand-up  shows)  and  one  was  a  documentary  film.  In 
volume, the majority of Viaplay and Netflix Originals were scripted series, while the majority of Discovery+ titles 
were reality series.  

Figure 63: Productions by format and VoD. 

series

reality series

reality film

film

documentary series

documentary film

HBO Max

Netflix

Viaplay

Discovery+

0

10

20

30

40

50

60

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

The most popular genre was reality/stand-up with 27 titles, followed by 17 crime productions, 11 titles in the 
comedy/romance category, eight dramas, seven documentaries and teen drama/YA titles, five actions/thrillers 
and  three  Sci-Fi/fantasy/horror  productions.  Volume  in  minutes  released  in  2020-2022  was  dominated  by 
reality/stand-up productions (8 851 min), followed by crime (5 039 min), and comedy/romance (2 249). 

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 Figure 64: Volume in minutes per genre and VoD 

10000
9000
8000
7000
6000
5000
4000
3000
2000
1000
0

Discovery+

Viaplay

Netflix

HBO Max

Source: Authors based on development of own dataset, including data from Lumière database, IMDbPro, The 
Movie Database, the VoD catalogues, academic literature and trade press 

4.4     Stakeholder views on the development of the audiovisual market 

Main trends 

The  associations  are  all  in  agreement  that  COVID-19  led  to  an  acceleration  of  changes  in  the  market.  A 
production association states that while VoD services were already expanding, COVID-19 meant that even 
more people subscribed to these and stayed at home to watch films since they could not go to the cinema 
anymore. So, while stakeholders see people slowly returning to their old habits, interest in cinemas and linear 
services has not returned to pre-pandemic levels. 

One association representing non-linear and linear media providers states that one of the main trends is the 
expansion of major US VoD services. While Netflix and Amazon were the key players in the market before the 
pandemic, in 2020, Disney+ was launched, followed more recently by Apple TV and Paramount+. VoD services 
are  now  expanding  their  base  in  Europe,  leading  to  greater  investment  in  European  content  to  appeal  to 
European audiences. In total, the Big 4 (Netflix, Amazon, Disney+, and Apple TV) invested about USD 2.9 
billion  in  Western  Europe  in  2021,  and  this  is  projected  to  grow  to  EUR  5  billion  by  2025.  A  production 
association points out that the drawback of this is that since this investment mostly comes from commissioning, 
the intellectual property rights remain in the US. Another association representing producers and distributors 
added that this is not ideal for promoting creative culture. 

The  same  association  representing  non-linear  and  linear  media  providers  mentions  that  this  has  led  to 
increased pressure on the European creative sector; production costs have grown and there is also a shortage 
of  talent.  Furthermore,  all  8  interviewed  organisations  representing  producers  point  out  that  independent 
producers have suffered. All these organisations mention that while large VoD services commission content 
from producers, producers have no intellectual rights over their own work. 

Some  associations  representing  players  across  the  value  chain  point  out  an  increase  in  the  demand  for 
unscripted  works.  While  associations  representing  linear  and  non-linear  services  claim  that  this  is  what 
consumers  want,  the  cultural  sector  has  suffered  from  this  development  according  to  producers’  and 
distributors’ associations.  

One association representing non-linear media providers mentioned that releasing a film simultaneously in the 
cinema and on VoD does not pose a threat to its success. In their view, tt allows for the work to reach an even 
wider audience than what would have been achieved with a cinematic release. It is an opportunity especially 
for smaller European films that may need time to catch the attention of audiences. 

A  non-linear  and  linear  media  providers  association  mentioned  that  co-productions  have  increased  in  an 
attempt by production companies to reduce costs. However, two associations representing producers said that 
co-productions  have  decreased  due  to  VoD  services  not  wanting  to  share  rights,  and  also  because  of 
insurance  issues  stemming  from  the  pandemic.  Another  noticeable  change  that  multiple  associations  of 

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producers and distributers have signalled is a reduction in investment in independent films and television, i.e., 
works  produced  outside  the  major  film  studio  system.  Recently,  according  to  an  association  representing 
producers, broadcasters have also started to demand more rights over the content, leaving the producers with 
no intellectual property rights. 

One  association  representing  linear  broadcasters  and  VoD  services  says  that  broadcasters  generally 
collaborate more with each other and are keen to engage in joint ventures. One example of this is broadcasters 
forming a joint venture to launch VoD services across Europe. However, the association notes that this can 
sometimes be problematic because of competition rules. The presence of US VoD services in the European 
market has also prompted an increase in instances where broadcasters pool their resources to create bigger 
works.  

On the question of collaboration with  independent producers, one association representing producers says 
that  while  producers  prefer  working  with  broadcasters  because  they  can  retain  ownership  of  their  work, 
broadcasters  are  facing  serious  competition  from  VoD  services,  and  this  has  caused  tensions  between 
producers and broadcasters. 

Most  organisations  are  of  the  view  that  collaboration  is  generally  a  positive  thing  and  frequently  occurs. 
However, collaboration with VoD services can be difficult, according to an association representing producers 
and distributors, especially from the contractual point of view. For producers, it can lead to them losing the 
rights for their own works to big VoD services, meaning that they are not able to generate a long-term income 
from them. This also prevents them from having a catalogue from which to invest in future productions. Overall, 
in their opinion, it is an unbalanced bargaining situation. 

According to an association representing non-linear and linear media providers, investment is still important 
and focused on fiction (drama, scripted comedy, thrillers, supernatural and horror). According to them, about 
EUR 3 billion is spent creating drama and scripted comedy in Europe. However, the overall consensus is that 
unscripted works are gaining in importance. According to an association representing producers, there has 
also been a fall in investments in feature films. A view shared by an association representing producers and 
distributors is that the investment decisions of linear services take into account the implementation of Article 
16 in specific countries. Alternatively, they also invest in high-end documentaries and fiction. Ultimately, these 
investments are often made by audiovisual groups that can afford to take risks. 

Overall, the associations interviewed points towards  a rising trend  in investments in  unscripted  works. The 
reason for this, according to a non-linear and linear media providers association, is that it was easier to produce 
these kinds of works while following protocols during the pandemic. The association claims that unscripted 
works  now  represent  three-quarters  of  titles  commissioned  because  they  cost  less  than  scripted  works. 
Therefore, while fiction drama is still important, unscripted programmes make up the bulk of commissions. 

Europe vs. US 

One  problem  mentioned  by  5  associations  interviewed  (one  association  representing  linear  and  non-linear 
services,  one  association  representing  producers  and  distributors,  and  three  associations  representing 
producers) is that big VoD players from the US have bigger budgets than European linear services. European 
linear services and VoD providers are therefore lagging behind in buying power. According to an association 
representing  non-linear  media  providers,  a  potential  reason  for  this  is  the  use  of  one  language  across  the 
whole  territory  of  the  US.  This  lack  of  language  barriers  represents  an  advantage  compared  with  Europe, 
where many countries use different languages. In addition, cultural and other differences make it difficult for 
local European linear services and VoD providers to expand at the same rate as their US counterparts.  

There is also an imbalance between linear and non-linear services according to a producers’ and distributors’ 
association. They consider that linear services have less purchasing power than non-EU global VoD services 
. This is partly due to linear services recouping their investments in their domestic market,  or in the limited 
number of markets in which they operate, whereas non-linear services recoup their investments in a global 
market. 

UK works  

An association representing producers and distributors brought up the fact that the UK does not have any state 
aid laws to which audiovisual works must adhere, in addition to having a very aggressive tax rebate policy. 
The same association went on to mention that on the whole, the UK is attracting American productions, which 
only  need  to  have  one  European  producer  to  qualify  as  a  European  work.  This  means  that  US/UK  co-
productions easily can qualify as European works, thereby leaving open a corridor for mostly American films 
to be qualified as European works.  

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Another reason put forward by a producers association for UK works having a greater reach and being more 
present  in  VoD  catalogues  is  that  their  language  is  more  commonly  understood.  In  this  sense,  another 
producers association mentions that, after Brexit, there has been a new trend of  co-productions that would 
have  been  otherwise  US-UK  co-productions,  moving  to  Ireland  –  also  an  English-speaking  country  –  to 
continue benefitting from Creative Europe and EU funding.  

An  association  representing  non-linear  and  linear  media  providers  says  that  the  share  of  UK  works 
broadcasted by linear media varies considerably by market. In Ireland, which has a common language with 
the UK, while remaining part of the EU, over 25% of Public Service Media (PSM) content comes from the UK, 
while Nordic markets carry around 15% of UK content and Germany around 10%. Therefore, in some markets, 
UK content makes up an important part of linear service schedules. According to the association interviewed, 
this situation has existed for several years and shows that there is audience demand for this content. 

Investments in content  

Associations  report  several  changes  when  it  comes  to  the  form/mechanisms  of  content  investment  (e.g., 
commissioned  works,  in-house,  others).  An  association  representing  non-linear  and  linear  media  providers 
states  that  there  has  been  an  increase  in  co-productions  due  to  increasing  costs;  an  increase  in  series  to 
attract new subscribers (long-term stories means securing long-term subscribers) according to an association 
representing distributors; and since dramas and comedies are expensive to make, there has also been a shift 
towards the unscripted genre which is cheaper to make, as pointed out by a few associations representing 
different players. Lastly, as noted above, there has been an increase in commissioning by VoD services, which 
means that investment in independent cinema has decreased according to an association representing non-
linear media providers. 

One association representing non-linear media providers sees collaboration with European broadcasters as 
an important step towards larger economies of scale. This is because most European VoD services are too 
small to invest in works directly by themselves. Since broadcasters are already established in the market and 
have a network, such collaboration makes sense. In the end, it leads to more tools and instruments that can 
be used to develop European content. 

When looking at the PSM and their corresponding VoD services, the content is mostly European since it caters 
for  the  demand  of  their  audiences,  according  to  an  association  representing  non-linear  and  linear  media 
providers. But even for media other than PSM, this association notes that VoD services mostly carry European 
content, demonstrating that it is important for their commercial success as the audience wants to see content 
from  their  own  country.  After  national  content,  an  association  representing  linear  broadcasters  and  VoD 
services states that the audience generally prefers US/UK content due to familiarity with the English language. 

Several associations representing linear and non-linear media providers state that their members are investing 
in  unscripted  works  due  to  financial  constraints.  One  association  representing  non-linear  media  providers 
states that unscripted works are longer, therefore keeping viewers engaged for longer. Another association 
representing  non-linear  media  providers  says  that  these  kinds  of  works  also  allow  to  generate  advertising 
revenue from product placements, as well as enabling producers to gain more traction by extending characters 
on  social  media.  However,  these  developments  represent  a  risk  for  producers  of  more  creative  works, 
according to an association representing producers and distributors. This is especially notable in the case of 
VoD  services  which  must  abide  by  the  30%  quota  –  which  does  not  exclude  unscripted  works  –  while 
attempting to reduce their costs. 

A non-linear media services association also states that the investment plans of linear and non-linear media 
services are dependent on traditional profit-making economic factors. Given the decline in growth, new projects 
are experiencing large budget cuts. Therefore, according to them these investments are under pressure in the 
medium-term especially if the return on investment is not good. 

The same association also says that while there are still huge production plans in UK, there has been a shift 
of productions towards the EU, which will in all likelihood impact the UK audiovisual industry significantly, as it 
was previously  allocated  large budgets to create international content and benefitted from UK works being 
labelled as European. 

4.5     Conclusions  

The audiovisual sector comprises approximatively 225 000 companies in EU27, EEA countries and the UK. 
The  highest  number  of  companies  is  in  the  production  sector  (179  000).  Between  2019  and  2022  the 
audiovisual market generated around EUR 200 billion and employed around 760 000 people. 

Business models in the audiovisual sector 

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The analysis of the types and spread of VoD business models in the European VoD market has revealed that 
mostly  EU-owned  incumbent  players  (broadcasters,  telecom  companies  and  diversified  media  groups) 
account for half (53%) of the services in the EU27 and UK that carry recent EU27+UK film and TV productions. 
However, these incumbent players run only a quarter (27%) of the catalogues in which this content circulates. 
In contrast to this, mostly US-owned Tech companies and services purely active in VoD account for less than 
a  fifth  of  services  (19%),  but  over  a  third  of  catalogues  (47%).  The  VoD  services  of  VoD-born  and  Tech 
companies have a much larger, often cross-European, footprint than those of incumbent players which are 
often restricted to single territories or geo-linguistic regions. Their different footprints become reflected in their 
catalogues through a larger presence of British and Spanish content for the Tech and VoD-born services and 
a greater reliance on content from large and small high production capacity countries by EU-owned services 
and incumbent players.  

Regarding  revenue  models,  the  services  of  private  incumbent  players  compete  with  VoD-born  and  Tech 
platforms for both subscribers and advertisers, though the rollout of AVoD  in Europe is expected not to be 
parallel to the scale in the US. Small and niche VoD-players have only limited options for advertising-funding. 
Regarding advantages through integration, Tech and VoD-born companies have begun to mimic the vertical 
integration of both diversified media corporations and telco providers by expanding into content production and 
playing increasingly important roles in the technological infrastructure of VoD distribution. The scale of US-
owned players from their home market as well as the financial power derived from the business lines outside 
VoD or even the media business are the basis for their presence across the European market, while EU-owned 
operations by mostly incumbent players focus on few territories either because of a lack of scope for costly 
expansion  (due  to  the  need  to  adapt  to  languages  and  culture)  or  because  their  public  remits  or  business 
strategies make it opportune to focus on one or a few markets. 

The European production market is large, fragmented, characterised by small companies and infrequent output 
for  many  of  them.  Though  making  up  over  half  (53%)  of  producers  that  could  be  identified  by  combining 
Lumiere VoD with TMDB and Orbis data, small producers in the sample account for less than a third (30%) of 
first productions, while the large and very large producers that make up less than one sixth of producers (15%) 
in the sample stand for close to half the  output (47%) that received VoD distribution. The content of larger 
companies also tends to circulate more widely than the content of small producers. Despite this difference in 
the overall circulation, no major difference between company sizes could be found when it comes to the types 
of VoD services on which their content circulates. 

An  analysis  of  levels  of  corporate  integration  reveals  that  companies  with  some  form  of  vertical  and/or 
horizontal  integration,  particularly  with  B2B  rights  distribution,  have  higher  levels  of  circulation  in  more 
catalogues  and  countries  than  independent  producers  without  integration.  Their  lower  levels  of  content 
circulation may also indicate limited opportunities for financing through the (pre-)sale of distribution rights for 
non-integrated independents. Among the large and very large producers it is public service broadcasters and 
producers in diversified vertically integrated media corporations in particular that are active as commissioners 
and (co-)producers. Public service broadcasters appear to be the strongest force in content production mostly 
through  their  role  as  commissioners.  The  recent  content  of  PSB  circulates  less  than  that  of  other  types  of 
producers, which may be due to PSBs’ VoD services national footprints, different genre profiles compared to 
private VoD competitors as well as windowing strategies.  

The opportunities of producers from different countries for circulating their content vary across different types 
of VoD services. Regarding company size, the data does not show a correlation between production company 
size  and  the  kinds  of  platforms  their  content  sells  to.  Recent  content  from  producers  in  English-speaking 
countries (GB, IE) and Spain circulated to a higher degree on Tech and VoD-born platforms respectively, which 
tend to have large footprints also beyond Europe. Recent content (2020/21) from producers in BE, IE, and DK 
circulated in a high number of catalogues of which a lower share were domestic, indicating export orientation. 
Producers in CZ, NL, IT, FI, FR and DE appear most reliant on circulation in domestic catalogues.   

Investments in European works 

The mapping and analysis of the eight case studies  on investments in  European works by various players 
provides  some  interesting  insights  into  recent  developments.  Most  importantly,  there  is  still  significant 
fragmentation between countries, ranging from funding requirements established by media legislation, the size 
of the market, and the players active in content production and acquisition. Due to this, generalisations and 
accurate  comparisons  between  the  eight  countries  are  only  possible  to  a  limited  extent,  based  on  each 
market’s unique characteristics as well as important differences in the availability and presentation of financial 
data. Besides, definitions used for reporting on data in, for example, annual reports differ between countries, 

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for example as regards what is included in costs and budgets that describe investments in European content, 
or what is part of a certain genre or not.  

Our analysis shows that, overall, investment in European works has been stable or increased in 2020-2021 
across diverse players, from PSB to commercial broadcasters, film funds and VoD players. COVID-19 had a 
considerable  impact  on  the  audiovisual  sector,  which  was  not  always  reflected  in  the  investments.  For 
example,  in  countries  such  as  Poland  and  France,  governments  provided  exceptional  grants  in  order  to 
compensate for losses incurred as a result of lower cinema attendance, and hence lower contributions to film 
funds.  

PSB investments remained stable in 2020-2021 and in some countries they increased. And even though public 
broadcasters might have suffered a decrease in funding, we found that this was not necessarily reflected in 
reduced investments in original programming. Furthermore, commercial broadcasters significantly increased 
their investments in original European content in 2021.  

For VoD players, investments in commissions have been growing, compared with acquisitions of European 
works in the form of original or exclusive content, which also secures higher investments. However, genres 
which are cheaper to produce (i.e., documentary) and entertainment content (i.e., reality-TV formats) and other 
variety programming have also been on the rise. Nevertheless, these trends are particularly present in stronger 
media markets, such as France, Germany and Italy. According to our data and industry reports, there are still 
significant differences between the volume of investments in Western and CEE markets, as well as between 
large and smaller media markets. 

In  general,  VoD  players  have  become  important  contributors  to  investment  in  European  content.  This  is 
primarily the case for large US VoD services, such as Netflix and Amazon Prime Video, which have increased 
their  overall  investment  in  European  content  considerably  in  the  last  few  years,  in  selected  markets.  It  is 
expected  that  services  such  as  Disney+,  HBO  Max,  and  AppleTV+  will  also  expand  their  slate  of  original 
European  content  in  the  coming  years.  Nordic  service  Viaplay  has  also  expanded  its  investments  across 
European  markets,  however  the  majority  of  these  are  co-productions  with  other  European  players,  mainly 
broadcasters,  and  investments  in  cheaper  formats  and  genres.  The  SVoD  model  is  still  a  developing 
endeavour for most European broadcasters and telecommunications services, as online services have yet to 
become  financially  sustainable  and  a  standalone  source  of  investment  in  exclusive  online-only  content,  as 
seen even in the cases of joint VoD services in Europe. 

In summary, our analysis shows that investment in European works by various players remains stable or has 
increased  even  under  financial  pressure.  VoD  services,  both  European  and  US-based,  have  become  an 
important  financial  source  for  the  production  of  European  works.  This  shows  that  investment  in  European 
content  is  seen,  even  under  financial  pressure,  as  a  viable  and  necessary  investment  for  future  growth. 
Nevertheless, strategic considerations continue to create large discrepancies in investments between stronger 
and weaker European media markets. In the case of VoD, our findings point to increasing foreign investment 
in content, both in volume and more expensive scripted formats in large media markets that already offer a 
strong subscriber base, such as France, Germany and Italy. Czechia is a clear outlier in the analysis, as it has 
received limited investment from both US and  pan-European players such as  Viaplay, since  it  is a weaker 
production market with a rather small potential for subscriber growth. However, the attention given to the CEE 
market (e.g. Poland) by Netflix and Viaplay demonstrates that investment in European works is a developing 
strategy also for non-Western European markets. 

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5.  Volume 3: Analysis of the audiovisual 
content offer 

5.1     Linear services – content offer 

5.1.1     Summary of the methodology 

The main objective of this task is to generate insights on the characteristics of the content offer available on 
the  audiovisual  market  in  the  case  of  a  sample  of  broadcasters  in  15  Member  States.  This  analysis  is 
conducted  in  the  context  of  the  revised  provisions  of  the  Audiovisual  Media  Services  Directive  and  its 
transposition  in  the  national  legislations.  It  focuses  particularly  on  the  provisions  concerning  the  share  of 
European productions, of independent productions and their distribution during prime time. 

Intrinsic to this aim, there are several research questions that we will address in this report:  

−  Considering the amount of qualifying time (i.e., the time allocated to qualifying productions) what is 

the share of European works and EU27 works in linear programming? 

−  What is the share of various types of productions (e.g., European, European co-productions, recent 

productions, etc.) scheduled for prime time (or other)? 

−  What is the share of independent works in linear programming? 

−  Considering  the  Member  States  within  the  scope  of  this  task,  what  is  the  share  of  non-domestic 

European works in all the European works scheduled for broadcasting?  

From  the  perspective  of  both  its  scope  and  the  methodology,  as  reflected  in  the  initial  proposal  and  the 
inception  report,  this  task  builds  on  the  2021  study  carried  out  by  a  consortium  led  by  Kantar  on  the 
implementation – from the perspective of linear services – of the provisions of the AVMS Directive.  Thus, in 
terms of the geographic scope of this task, we focused on fifteen Member States, building on the results of the 
previous study and expanding the scope from 11 to 15 EU Member States:  

a.  Member States covered in the present study and the previous one: Austria, Czechia, Germany, Spain, 

France, Hungary, Italy, Netherlands, Poland, Romania, and Sweden.  

b.  New Member States added to the current study: Estonia, Slovakia, Belgium, Denmark. 

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Figure 65: Study’s geographic scope 

The selection was done to represent Member States with different audio-visual markets as well as different 
geographies. As in the case of the previous study, these Member States were selected to represent: 

−  The largest audiovisual markets in the EU while also covering diversity between medium-sized and 

large markets. 

−  Diversity in terms of regions of the EU. 

−  Diversity in terms of market fragmentation. 

As a result, the data collection for linear services includes 15 Member States in total, achieving a coverage of 
almost 90% of the EU population. It also captures data for significantly more channels in each Member State 
compared to the previous study as there are currently over 900 channels included in total.  

In  line with the  previous version of the study, we used  as  the  main source of  data the  EPG of each linear 
service considered, as made public by the broadcasters. The process of acquiring the data had several stages. 
However, as opposed to the previous study, in which the entire process was performed manually, building on 
the lessons learnt, this time we transposed the process in a cloud-based environment, enabling us to upscale 
its components for them to be able to handle larger quantities of data.  

Collection of raw data  

The collection of the EPG data began on November 1st, 2022 and lasted until January 31st, 2023. During this 
period, on a day-to-day basis, we collected the available daily EPGs of more than 900 channels across the 15 
Member States within the scope of this assignment.  

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Due to the technical characteristics of the publicly available online data sources322 and of the software323 used 
to access the EPG streams, we performed an initial selection of the channels collected from each source by 
making a selection of the channels within the scope of this assignment by using the most up to date information 
provided by the European Audiovisual Observatory TV Audience Market Share country reports and the lists of 
channels within the annual reports submitted by the Member States on the AVMSD indicators. 

This approach enables us, on  the one hand, to compare the results of this study  with those from the study 
corresponding to the period 2015-2019 and, on the other hand, to put the values we achieved for the indicators 
of  interest  in  the  context  of  the  figures  reported  by  the  Member  States.  However,  given  the  significant 
differences between the  methodologies used to achieve the two sets of  indicators  – the self-reported ones 
present in the MS reports and the ones we calculated based on the content of the EPGs  – any comparison 
between the values needs to take those into account, when drawing any kind of inferences with regards to 
either the magnitude or the source of potential differences between the values. 

Considering the content of the information present in the EPG data, calculating the values for the indicators of 
interest would have been impossible without the help of additional, secondary - publicly available – data on 
the characteristics of the productions deemed eligible within the scope of the assignment.  

We enriched the EPG data that was collected with additional information on topics such as the identity of the 
production companies or their countries of origin with the help of publicly available information from IMDb. The 
process was carried out through two complementary approaches: 

1.  Using IMDb’s search function, we attempted to identify each eligible production in the IMDb content 
by its title - using a fuzzy match of at least 65% - with the titles in IMDb, and considering other important 
characteristics  of  the  title  such  as  the  name  of  the  director  and  release  date.  Once  the  title  was 
matched, using a web scrapping software, we collected the information from the matched IMDb entry 
and appended it to the EPG data. This approach proved particularly useful in the case of series in 
which the information on the production characteristics can vary across episodes. 

2.  Since there were cases in which the name of the EPG entry (and corresponding names of directors 
and release dates) could  have resulted  in  erroneous  results while doing the  matching  in IMDb, we 
devised  a  complementary  matching  approach  too.  This  method  matched  EPG  entries  with  IMDb 
entries using the title only and a similarity index between the EPG and IMDb titles of 95%. This way, 
we matched the EPG titles with the IMDb ones two times and subsequently compared the results to 
opt for the most accurate matching found.  

Once  the  data  had  been  enriched  with  the  production-focused  information  (i.e.,  companies  of  production, 
countries of production), the information for each EPG entry was stored into a country-based data set which 
was then processed and analysed with the help of a multi-step process that had as final output the indicators 
reported in this study:  

−  Step  1.  Conditional  re-coding  of  variables:  e.g.,  defining  the  prime-time  intervals  for  each  Member 
State and identifying whether each entry on the EPG schedule is within the prime-time interval or not;  

−  Step 2. Computing production-focused additional variables: e.g., counting the number of production 
companies for each production, mapping the country of origin for each company as European or not 
and classifying the production as European, European co-production, or other relevant categories; 

−  Step 3. Computing the time-related variables required for generating the indicators of interest: e.g., 
total  number  of  minutes  covered  by  the  EPG  data  per  channel  per  day,  total  number  of  minutes 
allocated to eligible works per channel per day, total number of minutes allocated to European and 
other relevant categories of productions per channel per day. 

The  achieved  values  for  the  target  indicators  (numbers  and  percentages)  are  presented  in  the  dedicated 
section, together with the technical details regarding the calculation procedure for each indicator. 

322 While the available sources allowed the download of bulk data, due to potential technical problems with each individual source, in order 
to ensure the coverage of as many as possible channels in each  Member State, we also identified and used multiple sources of EPG 
data. Thus, the bulk data contained duplicated channels which were filtered out post- collection.   

323 The  data  were  collected  using  Webgrab++  (http://www.webgrabplus.com/)  with  bespoke configurations for  each  of  the  15  Member 
States. 

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Channels covered per Member State 

As mentioned in the methodological overview, before the EPG data were collected, on a country-by-country 
basis, the final list of channels was built by taking those appearing in the Member State reports as eligible and 
by checking if any channels were missing when comparing them to those from the Audiovisual Observatory 
Yearbook  –  Country  Audience  data.  This  ensured  that  the  TV  channels  covered  during  the  data  collection 
process included most of those that fall under the AVMSD jurisdiction.  

As shown in the figure below, the number of channels covered in this analysis varies by Member State, ranging 
from 101 in Poland to 18 in Slovakia. The numbers of channels may differ from those reported in 2021 because 
of three main reasons. Firstly, since 2021, some channels have become non-operational and were therefore 
removed from the sample. Secondly, some channels have either reached over 0.3% market share, in which 
case  they  were  included  in  the  analysis,  or  lowered  their  market  share  to  below  0.3%  and  were  therefore 
removed.  Thirdly,  the  selection  process  for  choosing  the  final  channels  that  were  analysed  was  slightly 
changed compared to last time to make it more effective. Specifically, eligible channels from the EPG data 
were chosen before the data collection phase while previously they were identified once data was collected. 
For  most  Member  States,  the  same  channels  were  analysed  over  the  three-month  measurement  period 
(November 2022 to January 2023).324 

France presents the highest number of eligible channels (73), while Sweden has the lowest number (13). The 
data in the present report covers four additional Member States – Belgium, Denmark, Estonia and Slovakia. 

Figure  66:  Number  of  channels  analysed  for  each  Member  State  (based  on  November  2022  to 
January 2023 data) 

324 In some cases, the total number of channels decreased as the data collection process advanced due to issues with the EPG data 
sources. The web aggregators stopped making EPG data available for some channels. Under this scenario, there were two actions 
taken: 1) the team either replaced the EPG source of data with another one to ensure that all the initially identified channels have data 
or 2) if there was no alternative source for the EPG data, the initial one was used until the end of the data collection process. 

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Table 28: Number of channels analysed for each Member State (2021 and 2022) 

2022 

2021 

Number of channels 
analysed in the current 
study (2022) 

Number of 
channels 
analysed in the 
previous study 
(2021) 

Total number of eligible channels 
from the Member States (2021) 

Poland 

Belgium 

Italy 

Romania 

France 

Netherlands 

Hungary 

Austria 

Czechia 

Sweden 

Spain 

Germany 

Denmark 

Estonia 

Slovakia 

101 

93 

88 

78 

74 

66 

64 

60 

63 

59 

57 

48 

34 

26 

18 

58 

N/A 

60 

52 

81 

32 

58 

38 

65 

30 

74 

38 

N/A 

N/A 

N/A 

42 

N/A 

53 

37 

73 

21 

36 

22 

65 

13 

69 

37 

N/A 

N/A 

N/A 

Period covered by the data 

In  line  with  the  specifications  set  forth  in  the  inception  report,  the  collection  of  the  EPG  data  began  on  1 
November 2022 and continued until 31 January 2023 for most Member States. The current report uses all the 
data collected for each Member State over the 3-month period. As there were some Member States for which 
the EPG source of information had to be adjusted several times during the data collection process (due to the 
websites  changing  their  structure),  certain  days  registered  some  data  gaps  (especially  in  December).  To 
compensate for the missing data, we collected additional EPG data for 5 extra days in February for all Member 
States.  

Importantly, as it can be seen in the below figure, there is a large amount of data collected for each month and 
for each Member State. The graph presents the number of different titles that were collected for each month.  

In November 2022, the Polish television broadcast 102 496 titles in total on the 101 channels tracked. Italy 
registered a similarly high number of titles (in total, 90 739) on the 88 channels analysed. On the other hand, 
for Slovakia, there was a lower number of programmes broadcast during this month (in total, 21 874) across 
the 18 channels analysed. The months of December and January show similar patterns, with Poland, Italy and 
the Netherlands having the most programmes broadcast.  

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The main aim of this graph is, however, to show that the number of titles broadcast per Member State is similar 
across November, December and January, with only small variations. This is the case in all Member States 
analysed. As mentioned above too, in February, we collected additional titles to compensate for the missing 
data on some days.  

Figure 67: Number of EPG by Member State, by month (based on November 2022 to January 2023 
data) 

In addition, as shown in the below figure, the average daily number of TV programmes by  Member States 
tends to be overall correlated with the number of channels covered in each country, which indicates a high 
quality and readability of the data capture process. Moreover, having on average over 1 000 TV programmes 
collected daily ensures that the data is very representative of the linear services’ content offer. In fact, one of 
the main objectives of this study was to design a collection process that allows for retrieving high amounts of 
data automatically, which would have not been possible using a manual approach.  

Moreover, comparing the current figures with those from the previous study, between November 2022 and 
February 2023, the highest average number of EPG entries was observed in Poland, at 3 391, while the lowest 
was  found  in  Slovakia  with  741.  In  comparison,  France  had  the  highest  average  number  of  EPG  entries 
between  December  2020  and  February  2021,  standing  at  2  490,  while  the  lowest  number  of  EPG  entries 
during this period was observed in Sweden at 700. This shows that the number of average EPG entries has 
more  than  doubled  in  Sweden  and  increased  by  nearly  83%  in  Poland.  All  other  Member  States  saw  an 
increase, with the exception of France and Spain, where the average number of EPG entries remained the 
same. 

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Figure  68:  Average  number  of  EPG  entries  by  Member  State,  by  day  (based  November  2022  to 
January 2023 data) 

Table 29: Average number of EPG entries by Member State, by day 

Nov. 2022 – Jan. 2023 

Dec. 2020 – Feb. 2021 

Poland 

Italy 

Belgium 

Netherlands 

France 

Austria 

Germany 

Sweden 

Spain 

Romania 

Czechia 

Denmark 

Hungary 

Estonia 

3 391 

2 995 

2 552 

2 196 

2 186 

2 084 

1 726 

1 684 

1 616 

1 579 

1 542 

975 

790 

750 

1 855 

2 031 

N/A 

N/A 

2 490 

1 137 

1 091 

700 

2 012 

1 543 

1 400 

N/A 

1 776 

N/A 

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Slovakia 

741 

N/A 

Nov. 2022 – Jan. 2023 

Dec. 2020 – Feb. 2021 

Categories used in this chapter 

In line with the scope of the assignment, once the pre-processing of the data was completed, indicators were 
generated to estimate the key indicators of interest, as follows: 

a.  Qualifying time and qualifying works 

A  key  distinct  feature  of  the  project  consists  in  the  high  volume  of  data  collected  across  Member  States, 
channels, and time. Nevertheless, in addition to the implicit benefits of such data richness, the quantity of data 
also posed significant challenges in terms of its management and processing.  

Therefore,  the  identification  of  qualifying  programmes  to  which  Articles  16  and  17  apply:  all  programmes 
excluding  “news,  sports  events,  games,  advertising,  teletext  services  and  teleshopping”  –  needs  to  rely  as 
much  as  possible  on  information  either  present  in  the  collected  EPG  data  or  appended  through  post-
processing. Attempting to manually check or code more than two million entries across fifteen languages would 
prove to be an impossible research feat. The EPG data is very useful in this respect, as it contains the genre 
or category for nearly all TV programmes. The main challenge, however, was that the EPG data did not use a 
strict terminology for categories. For example, non-qualifying works that were sports were not always coded 
as ‘sports’ but as ‘football’, ‘tennis’, ‘Champions League’ or any other similar variation. The issue became more 
complex as various languages were  used too. Thus,  to  identify qualifying  works, we set  up a text analysis 
process  that  helped  us  identify  all  the  non-qualifying  categories  from  either  the  EPG  or  IMDb  data.  The 
rationale behind this approach is the following:  

•  At the first stage, during the data collection process, we built a comprehensive list consisting of all the 
categories that are not eligible (news, sports, games, advertising, teletext and teleshopping) in each 
of the languages of the Member States covered and English too. For this, we used the EPG data from 
the previous study (2021) which covered 3-months of data. This ensured that, although not entirely 
exhaustive, the final list of categories to exclude was close to perfect. The EPG sources of information 
in each Member State use either the official language(s) spoken or English. Thus, for each Member 
State, the list of categories to exclude were recorded both in the official language(s) spoken or English. 

•  Then, we optimised the web-grabber software to exclude TV programmes with any of these categories 
when searching for titles in the IMDb database. The information related to the categories of each title 
came from the EPG data itself 

•  Finally, when processing the data, we identified the qualifying works by looking at the information from 
the  EPG  data  and  excluding  those  titles  which  were  not  eligible  according  to  their  corresponding 
categories that we recorded during the first step. This way, for each work, we checked if the category 
is part of the list of non-eligible categories. If it was, then the time devoted to it was classified as non-
qualifying time.  

This process was significantly more effective than the one performed for the previous analysis, since using the 
EPG data related to the names of the categories leads to being able to categorize with a higher degree of 
accuracy  a  larger  number  of  productions.  The  reason  for  this  is  that  the  EPG  data  had  a  corresponding 
category for nearly all titles collected. Thus, the level of accuracy when identifying the qualifying works was 
very high.  

As a methodological caveat, we have considered as qualifying time all works which were not “news, sports 
events, games, advertising, teletext services and teleshopping”. However, due to the matching process, we 
could not retrieve the information required for the classification and analyses (e.g., name and country of origin 
of  production  companies,  etc.)  for  all  the  qualifying  works  (i.e.,  works  that  did  not  fall  within  the  above 
categories). This was the case because some of this information was not available in the IMDb database at 
the time of analysis. To mitigate this issue, where possible, such as in the case of the classification of qualifying 
works  into  the  European  or  non-European  category,  we  have  used  information  related  to  the  country  of 
production of the qualifying works already present in the EPG data collected. The existence of such cases 
explains, for example, apparent indicator inconsistencies such as the fact that when summing up the number 

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of titles where the names of the production companies were found is lower than that of titles where their country 
of origin was available. 

Moreover, it is important to note that if we were to redefine qualifying time as the sum of the time allocated to 
works that were identified in the IMDb database, the reported share of eligible time within each Member State 
pertaining to, for example, European works would potentially increase. As explained above too, the approach 
used  to  classify  a  work  as  qualifying  implied  checking  if  the  genre  or  category  was  not  part  of  the  list  of 
categories to exclude. The time allotted to these works represents the basis for calculation. Or, put it differently, 
this  is  the  denominator  for  all  the  indicators  when  calculating  the  shares.  However,  although  a  work  is 
considered as  qualifying, the country of origin is  not  necessarily known due to  not  matching it in the IMDb 
database or the EPG data missing this information. Thus, when dividing the time allotted to European works 
by qualifying works, there is a margin of errors stemming from not being able to classify some of the qualifying 
works as European or non-European.  

Following this approach, throughout the report, in line with the content of the AVMS Directive and the guidance 
received, the indicators are calculated based on the amount of qualifying time, defined as the amount 
of broadcasting time assigned to qualifying works. 

b.  European  productions  and  co-productions  within  qualifying  time,  Member  States,  and 

schedules 

To  distinguish  the  European  productions  and  co-productions  from  non-European  qualifying  works,  we 
operationalised the AVMS Directive definition of European works325 by analysing either the declared countries 
of origin (where available) or the country of origin of the production companies. Thus, we categorised the works 
as follows: 

•  European productions: those productions made by a single European production company/producer. 

•  European co-productions: productions where at least two production companies are involved and at 

least one of them is European. 

We have also operationalised the definition of European co-productions differently: 

•  European co-productions: productions where at least two production companies are involved and the 

majority of them are European. 

Thus, when producing graphs and tables for the percentage of European works (i.e., summing up European 
productions and European co-productions), we created two sets of figures: one using the first definition of a 
European co-production and another one using the second definition.  

c.  European productions and co-productions within prime time 

To classify the works as scheduled within or outside the prime-time interval, on a country-by-country basis, we 
identified the prime intervals and, depending on the scheduled start time and the country of scheduling, we 
classified each of the works accordingly.  

The table below shows the time intervals considered as prime time in each of the 15 Member States, in line 
with the audience market share data of the European Audiovisual Observatory – 2020 Yearbook data.  

Table 30: Prime Time intervals by Member State 

Member States 

Prime Time Interval 

Austria 

Czechia 

Germany 

20:00 – 23:00 

19:00 – 23:00 

20:00 – 23:00 

325 In line with the Article 1(1)(n) of the Directive, European works are those a) originating fromone of the EU Members States, b) originating 
from European third states which have ratified the European Convention on TransfrontierTransfontier Television of the Council of Europe 
and c) co-produced within the framework of agreements related to the audiovisual sector between the EU and third countries. 

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Member States 

Prime Time Interval 

France 

Hungary 

Italy 

20:00 – 23:00 

20:00 – 23:00 

20:30 – 22:30 

Netherlands 

19:30 – 23:00 

Poland 

Romania 

Spain 

Sweden 

Belgium 

Denmark 

Slovakia 

Estonia 

19:30 – 23:00 

19:00 – 23:00 

22:00 – 24:00 

19:00 – 23:00 

19:00 – 23:00 

19:00 – 22:00 

19:00 – 22:00 

18:00 – 23:00 

Source: EAO Yearbook for subscribers 

Within  the  report,  this  indicator  is  operationalised  as  the  amount  of  time  ascribed  to  works  classified  as 
European and scheduled to be broadcast within the prime-time intervals.  

d.  Domestic and non-domestic European works within qualifying time and Member States 

Domestic European works are defined as qualifying European works which are produced by the same Member 
State as that in which the work is scheduled for broadcasting in the EPG data. Specifically, the methodology 
used to identify domestic works consisted in analysing the origins of the production companies. If at least one 
of the production companies of a work originated in the Member State analysed, then it was classified as a 
domestic European work.  

Conversely, non-domestic European works are those European productions in which the country of production 
or  the  countries  of  origin  of  the  production  companies  differed  from  the  country  in  which  the  production 
wasscheduled for broadcasting. 

Following this functional definition, throughout this report the values for these indicators are operationalised 
and  expressed  as  the  share  of  time  allocated  to  the  above-defined  domestic  and  non-domestic  European 
works in the total amount of qualifying time.  

e. 

Independent  productions  and  co-productions  within  qualifying  time  Member  States,  and 
schedules 

The AVMSD does not include a definition of “independent production”.  In our current approach, in order to 
assess  whether  a  production  was  independent  or  not,  we  used  publicly  available  information 326, 327,328 to 
compile a list of over 2 000 producers and production companies across Europe classified as independent. 

326 Sources: https://www.cepi-producers.eu/our-members; https://www.euroVoD.org/members; 
https://www.europeanproducersclub.org/members Sources: https://www.cepi-producers.eu/our-members; 
https://www.euroVoD.org/members; https://www.europeanproducersclub.org/members 

327 https://www.euroVoD.org/members 

328 https://www.europeanproducersclub.org/members 

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According  to  the  methodology  used,  if  a  qualifying  European  work  was  produced  by  a  single  production 
company matched against the list, it was classified as an independent production.  

If there were at least two production companies for a work and all of them were identified as independent, the 
work was classified as an independent co-production. 

Where a qualifying work had at least two production companies at least one of which has been identified as 
independent  while  the  rest  have  not  been  identified  as  such,  the  work  was  considered  as  a  co-production 
between  independent  and  non-independent  production  companies.  This  indicator  is  labelled  as  “quasi-
independent European works”. This is the indicator that will be presented in more detail in this study, in section 
5.1.4     

Consequently, by applying this classification approach, the indicator throughout this report is expressed as the 
time ascribed to this category as a share of the time ascribed to qualifying works (i.e., qualifying time). 

The following was the step-by-step process implemented to identify quasi-independent European works: 

•  Firstly, Kantar Public used as a starting point the list of European independent production companies 

and producers built for the previous study conducted in 2020-2021. 

•  Secondly,  the  team  conducted  desk  research  to  identify  the  most  reliable  web  sources  for  further 
developing the list containing the names of independent production companies and producers from 
Europe.  The  sources  used  mainly  include  the  websites  of  European  and  national  assocications  of 
independent producers. 

o  CEPI,  the  European  Audovisual  Production  association,  represents  19  different  national 
associations  and  one  European  association  of  independent  producers  across  Europe.  The 
Kantar Public team ensured that  the  names of CEPI’s members were added  to their  list of 
independent producers. This implied  accessing  each  of the national associations’ websites 
and retrieving the names of independent producers and production companies at the Member 
State level. 

o  The European Producers CLUB (EPC) is an association gathering 170 influencial independent 
film  and  TV  drama  producers  coming  from  32  countries  in  Europe.  The  names  of  these 
independent producers were added to the list built by Kantar Public too. 

o  EuroVoD is a network of independent European Video on Demand platforms specialising in 
art-house films and independent cinema. Kantar Public only used EuroVoD to find additional 
independent  production  companies  from  Europe.  Although  EuroVoD  is  a  VoD  platform 
association,  this  was  still  useful  for  further  enriching  the  list  encompassing  independent 
producers from Europe. The EPG data contained all TV shows and movies broadcast on TV 
over  a  3-month  period  which  in  many  cases  included  movies  that  are  also  part  of  VoD 
catalogues.  EuroVoD’s  web  source  was  utilized  as  a  supplementary  tool  to  aid  in  the 
identification of additional names of independent producers. It served as a helper resources 
to expand our list of independent production companies by providing further information on 
where more names could be found.  

Importantly, before adding any independent producer or production company to the list, Kantar 
Public checked other websites too to ensure that the name found on any of the three sources 
mentioned above is certainly that of an independent producer.  

•  Thirdly, once the list reached the desired level of comprehensiveness, fuzzy matching techniques were 
used to find matches between the names of the production companies from the EPG data and those 
from the list built. A significant amount of time was invested in cleaning the names of the production 
companies to make them as comparable as possible given that in most cases the names from the 
EPG data and those from the list were slightly different (extra punctation marks or white spaces had 
to be accounted for).  

There are, however, two limitations to identifying  quasi-independent European works. Firstly, regardless of 
the time and resources invested in building a comprehensive list of independent production companies from 
Europe, there will always be some which were omitted. Secondly, identifying a quasi-independent European 
work implied finding the names of the production companies of the works from the EPG data (those broadcast 
on TV). This information was retrieved by matching the names of the works with the IMDB database. However, 
in some cases, the names of the production companies of the works from the EPG data were not available. 

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More information on the extent to which the names of the production companies were found can be seen in 
Figure 70. 

f.  Recent European productions and co-productions within qualifying time  

In line with the AVMS Directive, a qualifying work is classified as recent if the year of production is within five 
years of the year of scheduling. 

Following a similar approach as in the case of the previous categories of works, the indicator values reported 
in this study reflect the percentage of time covered by this category of productions in the total time ascribed to 
qualifying works. 

5.1.2     Qualifying works covered by the study 

By  applying  the  described  operationalisation  of  the  functional  definitions  detailed  previously,  this  section 
presents  an  overview  of  the  results  achieved  from  the  key  classification  process,  the  categorisation  of  the 
qualifying works and, implicitly, the intervals classified as qualifying time.  

The chart below presents the following information: 

−  The total number of entries (TV programmes) collected in November, December 2022 and January, 

February 2023 

−  The total number of qualifying entries which are defined as those TV programmes excluding news, 

sports and teleshopping. 

−  The  total  number  of  entries  (excluding  news,  sports  and  teleshopping)  for  which  we  were  able  to 

identify the countries of origins of the production companies. 

−  The  total  number  of  entries  (excluding  news,  sports  and  teleshopping)  for  which  we  were  able  to 

identify the names of the production companies. 

As  can  be  observed  in  the  figure  below,  the  total  number  of  entries  where  the  origins  of  the  production 
companies  were  available  is  sometimes  different  to  the  total  number  of  entries  where  the  names  of  the 
production  companies  were  found.  The  reason  for  this  is  because,  for  a  given  title,  the  IMDb  database 
sometimes  contains  both  this  information  while  it  sometimes  only  has  available  either  the  names  of  the 
production  companies  or  their  origins.  Likewise,  to  achieve  an  even  higher  degree  of  robustness  for  the 
indicators calculated, the countries of origin were retrieved both from the IMDb database and from the EPG 
data  itself.  The  former  was  possible  as  the  sources  of  information  that  the  web-grabber  software  uses 
sometimes contains this information too.  

Across all Member States, there is a significant number of qualifying works and works for which both the names 
of the production companies and their origins were identified.  

The total number of entries displayed below is considerably higher than for the 2020-2021 reporting period, 
with more than double the entries identified in Poland, and nearly double in Italy. The lowest number of entries 
was found in Sweden with 50 156 entries in 2020-2021, less than half of the current 158 282. 

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Figure 69: Number of  entries (TV programmes) available at each data collection stage (based on 
November 2022 to January 2023 data) 

The  figure  below  shows  the  exact  share  of  the  TV  programmes  for  which  the  countries  of  origin  of  the 
production companies and their names were identified in the IMDb database (out of the total number of entries). 
The percentage of entries where the origins of the production companies were found out of the total entries is, 
however, slightly higher in most Member States because, as stated above, the information from the EPG data 
was used too.  

Figure 70: Share qualifying entries out of the total number of entries available at each data collection 
stage (based on November 2022 to January 2023 data) 

The  indicators  on  the  percentage  of  European  works  and  EU  works  were  calculated  by  identifying  the 
European  works  from  those  TV  programmes  for  which  the  origins  of  the  production  companies  were 
available. This represents the basis for calculating the final percentages for these two indicators. As observed 
in the graph above, the percentage of identified works out of the total qualifying works varies by Member State. 

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It ranges from 61% in Sweden to 27% in Hungary. In most Member States, the number of works for which the 
country of origin was identified represents between 30% to 50% out of the total number of entries collected 
over the 3-month period. 

As explained in one of the previous sections too, the entries where  the names of production companies 
were found out of the qualifying entries represent the basis for calculating the final percentage of European 
independent producers.  

In terms of the total minutes covered in the EPG data and the corresponding qualifying time, in all cases, over 
2 million minutes’ worth of data were collected, as shown below. For Poland, Italy and Belgium, over 9 million 
minutes of TV programme data were registered. For all Member States, the figures are higher than during the 
2020-2021 reporting period, with the great increases in EPG time covered seen in the Netherlands (by 146%) 
in Poland (by 120%) and in Italy (by 89%). 

Figure 71: Total amount of time and qualifying time collected for each Member State, expressed in 
minutes (based on November 2020 to January 2023 data) 

5.1.3     All European works 

Integral to the study is the indicator of the share of European works out of the total qualifying time. The graphs 
below show this for each Member State. Germany at 81.3% has the highest share, while Romania at 17.2% 
has the lowest share. For most Member States, the share of European works ranges from 50% to 17%. The 
top three Member States with the highest share of European works are Germany, Spain and Poland. 

In the previous reporting period, Germany had the highest share of European works, although it was markedly 
lower, at 52.3%. Poland and Spain followed, with 48% and 45.4% respectively,  both values lower than the 
current  observations.  Romania  and  the  Netherlands  presented  the  lowest  share  of  European  works,  with 
around 28%, suggesting that this has gotten worse over time. Sweden’s share of European works, on the other 
hand, has improved by 20 percentage points. 

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Figure 72: Share of time allotted to qualifying European works (productions & co-productions) out of 
the total qualifying time 

Table 31: Share of qualifying European works (productions and co-productions), 2020-2021 and 2022-
2023 

2020-2021 

2022-2023329 

Germany 

Spain 

Poland 

Italy 

Sweden 

Belgium 

France 

Austria 

Slovakia 

Hungary 

52.3% 

45.4% 

48% 

40.7% 

29.4% 

N/A 

44.3% 

37.5% 

N/A 

31.1% 

81.3% 

68.0% 

59.4% 

53.3% 

49.8% 

41.8% 

35.0% 

34.1% 

25.3% 

24.0% 

329 For the current study, we used both the countries of origin stemming from the EPG data and from the IMDb database. However, the 
EPG data only had the countries of origin available for some Member States. Moreover, as the title matching procedure changed slightly 
compared to the previous study in 2021 to improve efficiency, the definition of qualifying works differs marginally too. 

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Netherlands 

Czechia 

Denmark 

Estonia 

Romania 

2020-2021 

2022-2023329 

28% 

39.3% 

N/A 

N/A 

28.6% 

23.9% 

22.4% 

21.8% 

18.6% 

17.2% 

In terms of EU works, Germany stands out too with 76.5% of the works being of EU origin. Spain ranks second 
with 61.1%  of EU  works, while Poland ranks third with 52.6%. Whereas Sweden  is in the top five  Member 
States with the highest share of European works, it is not  the case when analysing the share of EU works 
(ranking eight based on this indicator). That is to say that Sweden seems to have had a high share of European 
works but a lower share of EU works. On both indicators, Romania, Estonia, and Denmark register some of 
the lowest shares.  

Figure 73: Share of time allotted to qualifying EU works (productions & co-productions) out of the 
total qualifying time 

In the graph below, we aim to show the distribution of the percentage of European works across channels. 
Specifically, 56.8% of channels have between 0.7% and 40.1% of European works. The number of channels 
with more than 50% of European works (32% of the total number of channels) is lower than the number of 
channels that are under that threshold (68% of the total number of channels). Compared with the 2020-2021 
data, according to our research the proportion of channels with a share of European works between 0.7% and 
10.6%  is  now  1.7  times  higher,  representing  16.1%  of  the  sample  analysed  versus  9.5%  in  the  previous 
reporting period. On the other hand, the fraction of channels with 99% to 100% of European works is now 4 
times higher, increasing from 0.004% to 0.016% . The percentage of channels with more than 50% of European 
works increased by 2% compared with the 2020-2021 data (from 31% to 33%). 

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Figure 74: Number of channels according to share of qualifying European works – distribution across 
intervals (groupings) 

Looking at the highest and lowest amount of time allotted to European works among channels by  Member 
State, generally the channels with high amounts of European works are in Sweden, the Netherlands, Germany, 
Poland, Italy and Spain and the lowest in Belgium, Denmark, Estonia, Romania and Slovakia. In Germany, 
Estonia, Spain, Italy, Poland, Sweden and Slovakia, the channel with the lowest time is still higher than 5 000 
minutes of European programming, whereas the channels with the lowest amount of time allotted for European 
works in Denmark, Hungary, the Netherlands and Romania are at or under 200 minutes. In 2020-2021, the 
highest amount of time was allocated to European works by a channel in Spain with over 94 000 minutes, 
while a channel in Poland had the highest “lowest amount of time” allocated to European works, with 5 466 
minutes. 

Table 32: Channels with lowest and highest number of identified European works 
Channel 

Member State  Highest amount of time 

Lowest amount of time allotted 
to European works (in minutes) 

allotted to European 
works (in minutes) 

93 689 

88 055 

104 185 

119 400 

82 625 

50 161 

129 899 

98 947 

94 170 

124 066 

121 115 

128 129 

RTLup (HD) 

NJAM ! 

FILM EUROPE 

SWR Fernsehen RP 

TV2 Charlie 

Filmzone 

Telecinco 

POLAR+ 

TV Paprika 

Mediaset Extra (HD) 

BBC First 

TVP Seriale 

AT 

BE 

CZ 

DE 

DK 

EE 

ES 

FR 

HU 

IT 

NL 

PL 

2 350 

220 

470 

14 611 

120 

5 025 

10 760 

406 

120 

6 140 

200 

10 990 

Channel 

ProSieben Maxx 

Canal Z 

SLAGR & NOVA 

Comedy Central 

Lorry 

Duo 6 

Energy 

L'EQUIPE 

History 

Italia 1 

RTV Oost 

History (HD) 

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Member State  Highest amount of time 

Channel 

allotted to European 
works (in minutes) 

Lowest amount of time allotted 
to European works (in minutes) 

Channel 

RO 

SE 

SK 

70 560 

Happy Channel 

129 364 

81 477 

TV Finland 

Prima Plus HD 

105 

6 475 

10 285 

Crime + 
Investigation 

TLC (HD) 

Ťuki TV HD 

Furthermore,  in  Figure  75,  we  present  the  shares  of  European  works  (including  both  productions  and  co-
productions)  based  on  operationalising  the  definition  of  European  co-productions  slightly  differently.  More 
specifically, in the graphs and tables above, a European co-production was defined as any work where at least 
one  production  company  was  European.  The  graph  below  shows  the  shares  of  European  works  where  a 
European co-production was defined as any work where the majority of the production companies (over 50%) 
were European. Germany, Spain, Poland and Italy still form the top 4 Member States in terms of time allotted 
to qualifying European works. Although the share in Germany is somewhat lower (by 2.5pp) when considering 
the new definition, the shares in Spain, Poland, Italy, Belgium, Czechia, Hungary, Denmark, the Netherlands, 
Romania and Estonia are marginally higher. 

Figure 75: Share of time allotted to qualifying European works (productions & co-productions) out of 
the total qualifying time where European co-productions were operationalised differently 

The  figure  below  presents  the  distribution  of  the  percentage  of  European  works  across  intervals  when 
considering  the  definition  of  European  co-productions  as  productions  where  the  majority  of  the  production 
companies are European. This results in lower numbers of channels falling into categories of over 40.2% of 
European works. In particular, the number of channels showing 0.7%-10.6% of European works rises by 40 
compared to the situation when the usual definition is used, while the number of channels displaying over 60% 
of European works falls by 24. 

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Table 33: Number of channels according to share of qualifying European works – distribution across 
intervals (groupings) taking into account the different definition of European co-productions 

Considering the above-mentioned definition of European work, the channels with the highest amount of time 
allotted  to  European  works  can  be  found  in  Spain,  followed  by  Sweden  and  Poland.  This  doesn’t  change 
compared to when the other definition is used, although the values are lower. However, when looking at the 
lowest amount of time allotted to European works, Germany leads the list, followed by Italy and Poland. This 
differs from the situation where the other definition of European works is employed, as Italy’s allotted time is 
comparatively much higher, while Spain’s is lower. 

Table 34: Channels with lowest and highest number of identified European works where European co-
productions  were  defined  as  those  productions  having  the  majority  of  the  production  companies 
(European) 
Member 
State 

Channel 

Channel 

Highest amount of 
time allotted to 
European works (in 
minutes) 

Lowest amount of 
time allotted to 
European works (in 
minutes) 
870 
50 
295 
5 940 

AT 
BE 
CZ 
DE 

DK 
EE 
ES 
FR 
HU 
IT 

NL 
PL 

93 689 
85 186 
91 450 
114 285 

52 835 
39 565 
129 639 
88 297 
71 992 
124 066 

44 361 
127 104 

RTLup (HD) 
FRANCE 2 
FILM EUROPE 
RTLup 

TV2 Zulu 
Duo 4 
Telecinco 
POLAR+ 
Apostol TV 
Mediaset Extra 
(HD) 
SBS9 
TVP Seriale 

120 
1 364 
1 615 
302 
324 
4 360 

51 
1 920 

ProSieben Maxx 
NICKELODEON 
MTV 
Nickelodeon 
Ukraine Pluto TV 

Lorry 
Smartzone 
TNT 
L'EQUIPE 
Nat Geo (HD) 
DMAX (HD) 

Nickelodeon 
Discovery (HD) 

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Member 
State 

Highest amount of 
time allotted to 
European works (in 
minutes) 

Channel 

Channel 

Lowest amount of 
time allotted to 
European works (in 
minutes) 

RO 

42 240 

Mooz Ro 

50 

Nickelodeon (HD) 

128 752 
79 787 

SE 
SK 
As shown in the figure below, the share of UK works as a percentage of qualifying time is greatest in Sweden 
at 21.6%, followed by the Netherlands at 11.7% and Italy at 9.1%. Channels in Slovakia, Romania and Austria 
display the lowest shares of UK works, with 3.0%, 3.4% and 3.4% respectively. Most Member States’ channels 
share of UK works ranges from 5% to 8%. 

Discovery (HD) 
Lux TV 

TV Finland 
Prima Plus HD 

25 
1 010 

Figure 76: Share of UK works as a percentage of qualifying time (titles where at least one production 
company is from the UK) 

Share of UK Works

21.6%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

11.7%

9.1%

8.6%

7.9%

7.7%

7.6%

7.0%

6.2%

5.7%

5.3%

5.2%

3.4%

3.4%

3.0%

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5.1.4     Independent European works 

The results for the share of works that are produced by independent European production are detailed in the 
below figures. This section uses the indicator of quasi-independent European works across all the tables and 
graphs presented. The concept of “quasi-independent European works” was operationalised in such a way 
that a work is considered to fall into this group if at least one of the production companies were independent 
and European. Overall, the share of quasi-independent European works is fairly low across all the Member 
States (less than 3%). As mentioned in the methodological section too, there are two main caveats that deserve 
attention. Firstly, determining the share of quasi-independent European works involved the manual creation of 
a list comprising independent production companies and producers from Europe. While the list was extensive, 
it  is  possible  that  certain  independent  production  companies  were  unintentionally  excluded.  Additionally,  in 
order  to  identify  the  production  companies  associated  with  the  works  collected  from  the  EPG  data,  a 
supplementary  fuzzy  matching  procedure  was  employed  utiziling  the  IMDb  database.  The  matching 
techniques used proved to be highly effective in aligning the works across the two databases. Nonetheless, 
for certain works, the production company names could not be retrieved as they were absent from the online 
database. 

Belgium  and  France  present  the  highest  figures,  at  3.0%,  while  Slovakia,  Poland  and  Austria  lag  at  1.0%, 
1.4%, and 1.5%, respectively. These values appear lower than the shares calculated in the previous reporting 
period.  While  Romania  displayed  the  highest  share  of  such  works  in  that  period  with  4.6%,  this  has  now 
decreased to 1.6%. A similar pattern can be observed in the Netherlands, Sweden, Germany, and Austria. On 
the other hand, the share of independent works in France and Italy has risen considerably, from 1.7% and 
1.5% to 3.0% and 2.8%, respectively. 

Figure 77: Share of quasi-European independent works as a percentage of qualifying time (titles with 
at least one European independent producer) 

Share of Quasi-Independent European Works

3.5%

3.0%

3.0%

3.0%

2.9%

2.9%

2.8%

2.6%

1.8%

1.7%

1.6%

1.6%

1.6%

1.6%

1.5%

1.4%

1.0%

2.5%

2.0%

1.5%

1.0%

0.5%

0.0%

The table below presents the comparison between the share of quasi-independent European works from the 
2020-2021 study and the share from the current study:  

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Table 35: Share of quasi-independent European works, 2020-2021 and 2022-2023 

Share of quasi- independent European 
works 

2020-2021 

Share of quasi-independent European works 

2022-2023 

Belgium 

France 

The 
Netherlands 

Sweden 

Italy 

Denmark 

Estonia 

Czechia 

Germany 

Spain 

Hungary 

Romania 

Austria 

Poland 

Slovakia 

N/A 

11.3% 

8.1% 

10.8% 

9.2% 

N/A 

N/A 

16.2% 

7.9% 

6.7% 

9.3% 

11.3% 

9.3% 

7.3% 

N/A 

3.0% 

3.0% 

2.9% 

2.9% 

2.8% 

2.6% 

1.8% 

1.7% 

1.6% 

1.6% 

1.6% 

1.6% 

1.5% 

1.4% 

1.0% 

Table 36: Share of quasi-independent European works as a percentage of qualifying time by the 5 
channels with the highest market share 

Share 

Member State 

Austria 

Channel 

ORF 2330 

ORF 1 

ZDF 

RTL 

Vox 

Één 

330 The figure for ORF 2 was calculated by averaging the figures from ORF 2 Burgenland, ORF 2 Kärnten, ORF 2 Nö, ORF 2 
Oberösterreich, ORF 2 Salzburg, ORF 2 Steiermark, ORF 2 Tirol, ORF 2 Vorarlberg, ORF 2 Wien, and ORF 2 EUROPE. 

2.3% 

 5% 

2.1% 

1% 

0.5% 

0.6% 

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Member State 

Channel 

Share 

Belgium331 

Czechia 

Denmark 

Estonia 

France 

Germany 

VTM 

Vier 

La Une 

RTL TVi 

TV Nova 

ČT 1332 

Prima 

ČT 2 

Nova Cinema 

TV2 Denmark 

DR1 

TV2 Charlie 

DR2 

TV3 Danmark 

ETV 

Kanal 2 

TV3 Estonia 

ETV2 

Duo 4 

TF1 

France 2 

France 3 

M6 

France 5 

ZDF 

331 3 channels from the Flemish community and 2 channels from the French community 

332 The figure for ČT 1 was calculated by averaging the figures from ČT 1, ČT 1 JM, and ČT 1 SM. 

1.3% 

0.1% 

1.1% 

1.5% 

0% 

0.6% 

0.9% 

1.5% 

3.9% 

0.6% 

1.6% 

4% 

18.8% 

2.5% 

0.2% 

1.7% 

1.8% 

1.2% 

6.2% 

1.4% 

0.7% 

0.7% 

2% 

0.9% 

2% 

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Member State 

Channel 

Share 

Hungary 

Italy 

Netherlands 

Poland 

Romania 

One 

RTL 

SAT.1 

VOX 

TV2 

RTL Klub 

Duna TV 

ATV 

Super TV2 

RAI Uno 

Canale 5 

RAI Tre 

RAI Due 

Italia 1 

NPO 1 

RTL 4 

SBS 6 

NPO 2 

NPO 3 

Polsat 

TVP 1 

TVN 

TVP 2 

TVN24 

PRO TV 

Antena 1 

Kanal D 

0.7% 

0.8% 

0.9% 

0.7% 

2.7% 

3.3% 

4.5% 

0% 

3.3% 

0.5% 

0.9% 

1.5% 

0.8% 

5.4% 

0% 

1.2% 

0.1% 

0.4% 

0.7% 

3.6% 

1.6% 

4.9% 

2.3% 

0% 

0.6% 

0.6% 

0.3% 

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Share 

Member State 

Slovakia 

Spain 

Sweden 

Channel 

National TV 

Prima TV 

TV Markiza 

TV Joj 

Jednotka 

Television Doma 

Dvojka 

Antena 3 

La 1 

La Sexta 

Cuatro 

La 2 

SVT-1 

TV4 

SVT-2 

Kanal 5 

TV3 

8.9% 

0.9% 

1.7% 

1.1% 

0.8% 

1% 

3.1% 

1.1% 

0.7% 

1.2% 

0.3% 

0.6% 

0.2% 

3.4% 

1% 

0.4% 

1.9% 

−  Belgium and France have the highest share of European independent works as a percentage of all 

works, at 3.0%. On the other hand, Slovakia has the lowest share with 1%.  

−  However, some Member States have channels with larger shares of European independent works. In 
Austria, ORF 1 has the highest share at 5%. Duo 4 in Estonia has a share of European independent 
works at 6.2%. Nova Cinema at 3.9% is the channel with the highest share in the Czechia. In Denmark 
this is DR2 with 18.8%. In Italy, Italia 1 is the channel with the highest share of European Independent 
works. In Poland, TVN is the channel with the highest share. In Spain, this channel is La Sexta with 
1.2%. Duna TV has the highest share in Hungary at 4.5%, and in the Netherlands RTL 4 occupies the 
top spot regarding the share of European independent works, at 1.2%. In Slovakia, however, the share 
of  European  independent  works  is  somewhat  higher  with  Dvojka  being  the  highest  with  3.1%.  In 
Sweden, the highest share belongs to TV4 with 3.4%. 

Compared to the values gathered in the previous reporting period, the shares of quasi-independent 
European works reported in the table above appear lower – on average, 7% lower among the Member 
States analysed. The highest differences are observed in Czechia (difference of 14%) and Romania 
(difference of nearly 10%). In Austria, while ORF 2 and ORF 1 had 7.2% and 17.4% of such works in 
2020-2021, these figures are now found to stand at 2.3% and 5% respectively. Similarly, while NPO 3 
in the Netherlands had a share of 5.3% in 2020-2021, this has now fallen to 0.7%. Similar decreases 
can  be  observed  across  channels  and  Member  States.It  is  important  to  note  that  the  same 

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methodology was applied both for the study in 2020-2021 and the current one in terms of identifying 
the quasi-independent European works and subsequently calculating the corresponding shares out of 
the total qualifying time. Nevetheless, the differences could be associated to the additional channels 
added in each Member State compared to the 2020-2021 analysis. Some of the channels included in 
the current study are small channels too for which it was more challenging to identify the production 
companies of the works.  

5.1.5     Recent European works 

This section details the share of recent European works as a percentage of  the qualifying time. Specifically, 
we focused on the titles produced in the last 5 years. The results are shown on a country and channel basis 
in the below figures. 

According to the figure below, the share of recent European works is highest in Belgium, with 10.5%, followed 
by France and Italy, with 9.8% and 9.4% respectively. Hungary, Spain and Denmark show the lowest values, 
at 2.4%, 3.5% and 3.6% respectively. For the majority of the Member States, the share of recent European 
works  ranges  from  4.5%  to  9%.  Compared  to  the  values  found  in  the  previous  reporting  period,  they  now 
appear lower in all Member States besides France and Hungary, where a small increase can be noted, from 
9.2% to 9.8%, and from 2.2% to 2.4%, respectively.  

Figure  78:  Share  of  recent  European  works  as  a  percentage  of  qualifying  time  (all  titles  excluding 
news and sports) 

Share of Qualifying Recent European Works

9.8%

9.4%

8.9%

8.7%

8.1%

12.0%

10.5%

10.0%

8.0%

6.0%

4.0%

2.0%

0.0%

6.0%

5.9%

5.5%

5.1%

4.8%

4.5%

3.6%

3.5%

2.4%

Table 37: Share of recent European works as a percentage of qualifying time, 2020-2021 and 2022-
2023 

Belgium 

2020-2021 

N/A 

2022-2023 

10.5% 

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2020-2021 

2022-2023 

France 

Italy 

The Netherlands 

Germany 

Sweden 

Austria 

Poland 

Estonia 

Czechia 

Slovakia 

Romania 

Denmark 

Spain 

Hungary 

9.2% 

18.9% 

0.9% 

29.1% 

14.3% 

20.8% 

28.2% 

N/A 

11.8% 

N/A 

10.0% 

N/A 

28.1% 

2.2% 

9.8% 

9.4% 

8.9% 

8.7% 

8.1% 

6.0% 

5.9% 

5.5% 

5.1% 

4.8% 

4.5% 

3.6% 

3.5% 

2.4% 

Table 38: Share of recent European works as a percentage of qualifying time by the 5 channels with 
the highest market share 

Share 

Member State 

Austria 

Belgium334 

Channel 

ORF 2333 

ORF 1 

ZDF 

RTL 

Vox 

Één 

VTM 

Vier 

La Une 

333 The figure for ORF 2 was calculated by averaging the figures from ORF 2 Burgenland, ORF 2 Kärnten, ORF 2 Nö, ORF 2 
Oberösterreich, ORF 2 Salzburg, ORF 2 Steiermark, ORF 2 Tirol, ORF 2 Vorarlberg, ORF 2 Wien, and ORF 2 EUROPE. 

334 3 channels from the Flemish community and 2 channels from the French community 

10.7% 

6.9% 

12.7% 

8.3% 

5.2% 

10.2% 

10.1% 

7.8% 

26.7% 

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Share 

Member State 

Czechia 

Denmark 

Estonia 

France 

Germany 

Channel 

RTL TVi 

TV Nova 

ČT 1335 

Prima 

ČT 2 

Nova cinema 

TV2 Denmark 

DR1 

TV2 Charlie 

DR2 

TV3 Danmark 

ETV 

Kanal 2 

TV3 Estonia 

ETV2 

Duo 4 

TF1 

France 2 

France 3 

M6 

France 5 

ZDF 

One 

RTL 

SAT.1 

335 The figure for ČT 1 was calculated by averaging the figures from ČT 1, ČT 1 JM, and ČT 1 SM. 

4% 

6.5% 

7% 

4.7% 

3.5% 

6.1% 

6.8% 

9.1% 

3% 

6.6% 

3.4% 

5.3% 

5.2% 

7.1% 

8.3% 

14.1% 

6.8% 

14.1% 

10.8% 

4.5% 

6.9% 

19.4% 

14% 

11.7% 

19.2% 

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Member State 

Channel 

Share 

Hungary 

Italy 

Netherlands 

Poland 

Romania 

Slovakia 

VOX 

TV2 

RTL Klub 

Duna TV 

ATV 

Super TV2 

RAI Uno 

Canale 5 

RAI Tre 

RAI Due 

Italia 1 

NPO 1 

RTL 4 

SBS 6 

NPO 2 

NPO 3 

Polsat 

TVP 1 

TVN 

TVP 2 

TVN24 

PRO TV 

Antena 1 

Kanal D 

National TV 

Prima TV 

TV Markiza 

3.6% 

15.1% 

16.9% 

4.2% 

0.4% 

13.7% 

25.1% 

3.8% 

10.1% 

11.6% 

2.1% 

14.8% 

4.4% 

21.7% 

13.1% 

14.6% 

8.7% 

14.8% 

6.5% 

12.7% 

1.6% 

6.6% 

6% 

25.4% 

1.9% 

1.6% 

7.1% 

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Member State 

Spain 

Sweden 

Share 

Channel 

TV Joj 

Jednotka 

Television Doma 

Dvojka 

Antena 3 

La 1 

La Sexta 

Cuatro 

La 2 

SVT-1 

TV4 

SVT-2 

Kanal 5 

TV3 

11.4% 

2.8% 

1.9% 

2.7% 

12.3% 

9.4% 

0.5% 

7.1% 

5.4% 

19.6% 

10.4% 

13.9% 

29.2% 

2.6% 

− 

In Belgium, one channel is by far higher than the others with respect to recent European work share 
at 26.7% (La Une). In Austria, ZDF shows 12.7% of recent European works. In the Czechia, ČT1 is 
the highest with 7%. In Denmark, it is somewhat higher with DR1 having 9.1%. In Estonia, Duo 4 has 
a  considerably  higher  share  than  other  channels,  with  14.1%.  France  2  and  France  3  are  the  two 
channels with the highest shares in France, with 14.1% and 10.8% respectively. The channel with the 
highest share in Poland is TVP 1. In Germany, ZDF is the channel with the highest share of recent 
European works at 19.4%. In Hungary, RTL Klub has nearly 17% of recent European works. 

−  RAI Uno is the channel with the highest share in Italy with 25.1%. The Netherlands has one channel 
with more than 20% of recent European works with SBS 6 at 21.7%. Romania has Kanal D at 25.4% 
of recent European works. In Slovakia, the shares of recent European works are quite lower with TV 
Joj being the highest at 11.4%. This is similar to Spain with Antena 3 having 12.3%. In Sweden, Kanal 
5 is the channel with the highest share of 29.2 %. 

−  The  shares  of  recent  European  works  are  generally  lower  compared  to  the  numbers  calculated  in 

2020-2021, across the channels and Member States considered. 

5.1.6     Share of prime time dedicated to European works 

This section provides an analysis on the shares of European works showing at prime time. We have examined 
the shares of time spent on European works showed  in prime time with respect to the total time spent on all 
works excluding news, sports, and teleshopping. The results are calculated on a country and channel basis. 

The highest share of European works appears to be shown at prime time in Germany, with 11.1%. This is 
followed by Sweden and Belgium, with 10.1% and  9.9% respectively. The lowest share  is in Slovakia, with 
3.2%, and in Denmark and Austria, with 3.6% each. More than half of the Member States have a share ranging 
from 4% to 6.5%. Compared to the previous reporting period, the share of European works shown at prime 
time is currently lower in all Member States.  

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Figure 79: Share of European prime time works as a percentage of qualifying time (all titles excluding 
news and sports) 

Share of Qualifying European Works - Prime Time

12.0%

11.1%

10.0%

10.1%

9.9%

8.0%

6.0%

4.0%

2.0%

0.0%

8.1%

6.2%

5.3%

4.5%

4.4%

4.3%

4.1%

4.0%

4.0%

3.6%

3.6%

3.2%

Table  39:  Share  of  European  prime  time  works  as  a  percentage  of  qualifying  time,  2020-2021  and 
2022-2023 

2020-2021 

2022-2023 

Germany 

Sweden 

Belgium 

Poland 

Spain 

Romania 

Czechia 

France 

The Netherlands 

Hungary 

Estonia 

Italy 

Austria 

13.1% 

21.3% 

N/A 

18.2% 

10.1% 

19.4% 

20.1% 

13.2% 

19.6% 

17.9% 

N/A 

8.4% 

13.0% 

11.1% 

10.1% 

9.9% 

8.1% 

6.2% 

5.3% 

4.5% 

4.4% 

4.3% 

4.1% 

4.0% 

4.0% 

3.6% 

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Denmark 

Slovakia 

2020-2021 

2022-2023 

N/A 

N/A 

3.6% 

3.2% 

Table 40: Share of European prime time works as a percentage of qualifying time by the 5 channels 
with the highest market share 

Share 

Member State 

Austria 

Belgium337 

Czechia 

Denmark 

Channel 

ORF 2336 

ORF 1 

ZDF 

RTL 

Vox 

Één 

VTM 

Vier 

La Une 

RTL TVI 

TV Nova 

ČT 1338 

Prima 

ČT 2 

Nova cinema 

TV2 Denmark 

DR1 

TV2 Charlie 

DR2 

TV3 Danmark 

336 The figure for ORF 2 was calculated by averaging the figures from ORF 2 Burgenland, ORF 2 Kärnten, ORF 2 Nö, ORF 2 
Oberösterreich, ORF 2 Salzburg, ORF 2 Steiermark, ORF 2 Tirol, ORF 2 Vorarlberg, ORF 2 Wien, and ORF 2 EUROPE. 

337 3 channels from the Flemish community and 2 channels from the French community 

338 The figure for ČT 1 was calculated by averaging the figures from ČT 1, ČT 1 JM, and ČT 1 SM. 

8.3% 

3.6% 

8.3% 

1.8% 

3% 

19.8% 

17.2% 

17.4% 

21.9% 

22.4% 

4% 

11.6% 

8.4% 

8.2% 

8.5% 

4.3% 

8.5% 

8.7% 

4% 

5% 

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Member State 

Estonia 

France 

Germany 

Hungary 

Italy 

Netherlands 

Channel 

ETV 

Kanal 2 

TV3 Estonia 

ETV2 

Duo 4 

TF1 

France 2 

France 3 

M6 

France 5 

ZDF 

One 

RTL 

SAT.1 

VOX 

TV2 

RTL Klub 

Duna TV 

ATV 

Super TV2 

RAI Uno 

Canale 5 

RAI Tre 

RAI Due 

Italia 1 

NPO 1 

RTL 4 

Share 

6.2% 

5.3% 

4.3% 

5.2% 

7.7% 

6.5% 

10.9% 

10.4% 

8.3% 

8% 

16.6% 

12.2% 

14.1% 

13.4% 

11.4% 

5.6% 

9.6% 

7.6% 

0% 

6.7% 

3.8% 

7.3% 

2.1% 

2.5% 

1.8% 

11.3% 

4.5% 

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Member State 

Channel 

Share 

Poland 

Romania 

Slovakia 

Spain 

Sweden 

SBS 6 

NPO 2 

NPO 3 

Polsat 

TVP 1 

TVN 

TVP 2 

TVN24 

PRO TV 

Antena 1 

Kanal D 

National TV 

Prima TV 

TV Markiza 

TV Joj 

Jednotka 

Television Doma 

Dvojka 

Antena 3 

La 1 

La Sexta 

Cuatro 

La 2 

SVT-1 

TV4 

SVT-2 

Kanal 5 

7.5% 

10.6% 

6.2% 

6.1% 

11.2% 

8.1% 

13.4% 

1.3% 

14% 

19.6% 

15.7% 

3.9% 

5.2% 

3.8% 

7% 

2.5% 

0.6% 

1.9% 

9.1% 

9.9% 

5.7% 

4.9% 

8.9% 

32.4% 

19.8% 

42.1% 

13.2% 

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Member State 

Channel 

TV3 

Share 

6.1% 

− 

− 

In Austria, the channels with the highest shares of European works during prime time are ORF2 and 
ZDF, registering 8.3% each. In Belgium, La Une and RTL TVI occupy the top 2 spots, with 21.9% and 
22.4% respectively. In the Czechia, ČT 1 is the channel with the highest share at 11.6%. In Denmark, 
it is TV2 Charlie with 8.7%. In Estonia, ETV and Duo 4 are the channels with the highest shares overall, 
with 6.2% and 7.7% respectively. In France, France 2 and France 3 are the channels with the highest 
share of European works during prime time at 10.9% and 10.4% respectively. In Germany, the channel 
with the highest share is ZDF with 16.6% of European works during prime time. 

In Hungary, the channel with the highest share of European works during prime time is RTL Klub with 
9.6%. Italy has Canale 5 with the highest share at 7.3%. In the Netherlands, the two channels with the 
highest shares are NPO 1 and NPO 2, both exceeding 10% with 11.3% and 10.6% respectively. TVP 
1 and TVP 2 are the two highest channels in Poland at 11.2% and 13.4% respectively. Antena 1 has 
a share of 19.6%, the highest in Romania. TV Joj is the channel with the highest share of European 
works  during  prime  time  in  Slovakia  at  7%.  In  Spain,  the  channel  with  the  highest  share  is  La  1, 
standing at 9.9%. In Sweden, two channels exceed 30% of European works during prime time: SVT-
1 with 32.4% and SVT-2 with 42.1%. 

−  Compared with  the figures reported, the ones  in the table above appear lower  across  the different 
channels,  although  some  channels  have  seen  an  increase  in  the  share  of  European  works  during 
prime time. For example, SVT-2 in Sweden had a share of 10.4% in 2020-2021, which has more than 
quadrupled since then. 

5.1.7     Domestic European works out of qualifying time & domestic works within European and 
EU27 works 

In this section, we present the results of the share of works originating from the Member State being analysed, 
or domestic works. We investigate the amount of time spent on works where at least one of the production 
companies originate from the Member State being analysed as a share of the total amount of time spent on 
works that are neither news, sports nor teleshopping (qualifying works) by Member State and channel. The 
results are shown in the below graph and table. 

In the last part of this section, we also present the share of domestic works within European and EU27 works. 
More  specifically,  for  these  two  indicators,  the  share  was  calculated  as  the  percentage  of  time  allotted  to 
domestic works out of the total time allocated to European and EU27 works. 

The highest share of domestic works is shown in Germany, with 61.6%. This is followed by Spain and Poland, 
with 51.5% and 42.9%, respectively. Estonia displays the lowest share of domestic works, at 1.9%. The shares 
in  Romania  and  Czechia  are  also  particularly  low,  with  5.3%  and  5.9%  respectively.  Most  Member  States 
present shares of domestic works between 5% and 11%. Compared with the shares observed in 2020-2021, 
Germany  and  Spain  remain  in  the  top  3,  but  with  much  higher  shares,  noting  increases  of  22%  and  20% 
respectively. Hungary’s share of domestic works has increased threefold, while Sweden’s share is more than 
2.5 times what it was in 2020-2021. However, certain Member States have seen marginal decreases, such as 
Romania losing 1 percentage point since 2020-2021. 

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Figure 80: Share of domestic works as a percentage of qualifying time (all titles excluding news, sports 
and teleshopping) 

Share of Domestic Works

70.0%

60.0%

61.6%

50.0%

40.0%

30.0%

20.0%

10.0%

0.0%

51.5%

42.9%

34.1%

26.0%

19.4%

11.1%

10.2%

9.9%

8.0%

7.5%

6.5%

5.9%

5.3%

1.9%

Table 41: Share of domestic works as a percentage of qualifying time, 2020-2021 and 2022-2023 

2020-2021 

2022-2023 

Germany 

Spain 

Poland 

Italy 

France 

Sweden 

Belgium 

Hungary 

Denmark 

Austria 

Slovakia 

The Netherlands 

Czechia 

38.9% 

19.6% 

16.6% 

12.0% 

30.9% 

7.2% 

N/A 

3.3% 

N/A 

5.6% 

N/A 

9.1% 

9.2% 

61.6% 

51.5% 

42.9% 

34.1% 

26.0% 

19.4% 

11.1% 

10.2% 

9.9% 

8.0% 

7.5% 

6.5% 

5.9% 

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Romania 

Estonia 

2020-2021 

2022-2023 

6.0% 

N/A 

5.3% 

1.9% 

Table  42:  Share  of  domestic  works  as  a  percentage  of  qualifying  time  by  the  5  channels  with  the 
highest market share 

Member State 

Austria 

Belgium340 

Czechia 

Denmark 

Channel 

ORF 2339 

ORF 1 

ZDF 

RTL 

Vox 

Één 

VTM 

Vier 

La Une 

RTL TVi 

TV Nova 

ČT 1341 

Prima 

ČT 2 

Nova cinema 

TV2 Denmark 

DR1 

TV2 Charlie 

Share 

35% 

11.8% 

6.6% 

0.6% 

0.3% 

51% 

57.8% 

73.7% 

55.8% 

44.7% 

29.5% 

40.3% 

21% 

11.8% 

8.9% 

37.8% 

21.4% 

13% 

339 The figure for ORF 2 was calculated by averaging the figures from ORF 2 Burgenland, ORF 2 Kärnten, ORF 2 Nö, ORF 2 
Oberösterreich, ORF 2 Salzburg, ORF 2 Steiermark, ORF 2 Tirol, ORF 2 Vorarlberg, ORF 2 Wien, and ORF 2 EUROPE. 

340 3 channels from the Flemish community and 2 channels from the French community 

341 The figure for ČT 1 was calculated by averaging the figures from ČT 1, ČT 1 JM, and ČT 1 SM. 

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Member State 

Channel 

Share 

Estonia 

France 

Germany 

Hungary 

Italy 

DR2 

TV3 Danmark 

ETV 

Kanal 2 

TV3 Estonia 

ETV2 

Duo 4 

TF1 

France 2 

France 3 

M6 

France 5 

ZDF 

One 

RTL 

SAT.1 

VOX 

TV2 

RTL Klub 

Duna TV 

ATV 

Super TV2 

RAI Uno 

Canale 5 

RAI Tre 

RAI Due 

Italia 1 

11.3% 

16.7% 

13.9% 

8.7% 

3% 

3.5% 

2.8% 

14.8% 

58.1% 

29.8% 

27.9% 

32.7% 

71.4% 

62.3% 

81.2% 

87.3% 

41% 

19.5% 

42.4% 

15.4% 

4.3% 

27.2% 

61.3% 

66.9% 

42% 

23.8% 

21.5% 

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Member State 

Channel 

Share 

Netherlands 

Poland 

Romania 

Slovakia 

Spain 

Sweden 

NPO 1 

RTL 4 

SBS 6 

NPO 2 

NPO 3 

Polsat 

TVP 1 

TVN 

TVP 2 

TVN24 

PRO TV 

Antena 1 

Kanal D 

National TV 

Prima TV 

TV Markiza 

TV Joj 

Jednotka 

Television Doma 

Dvojka 

Antena 3 

La 1 

La Sexta 

Cuatro 

La 2 

SVT-1 

30.5% 

26.6% 

21.9% 

30.4% 

13.7% 

54.3% 

39.6% 

47.6% 

60.6% 

63.6% 

27.5% 

17.4% 

8.5% 

9.2% 

8.2% 

21% 

28.7% 

8.3% 

7.5% 

3.5% 

60.7% 

65.4% 

91% 

84.9% 

47.4% 

69.4% 

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Member State 

Channel 

Share 

TV4 

SVT-2 

Kanal 5 

TV3 

83.1% 

47.6% 

57% 

15.3% 

− 

− 

In Austria, the channel with the highest share of domestic works is by far ORF 2 with 35%. In Belgium, 
the channel with the highest share is Vier at 73.7%.   3 more channels in this Member State have a 
share of domestic works greater than 50%: Één (51%) VTM (57.8%) and La Une (55.8%). In Czechia, 
the channel with the highest share is ČT 1 with 40.3%. In Denmark, the channel with the highest share, 
TV2 Denmark, reaches 37.8%. In Estonia, no channel reaches higher than 10% other than ETV at 
13.9%. In France, these values are higher, with France 2 showing the highest proportion of domestic 
works, namely 58.1%. In Germany, two channels have more than 80% domestic works: RTL (81.2%) 
and SAT.1 (87.3%). 

In Hungary, the channel with the highest share is RTL Klub with 42.4% and in the Netherlands, this is 
NPO 1 with 30.5%, followed closely by NPO 2 with 30.4%. In Italy, Canale 5 is the channel with the 
highest share of domestic works, with 66.9%. Two channels in Poland have a share greater than 60%: 
TVP  2  (60.6%)  and  TVN24  (63.6%).  In  Romania,  PRO  TV  occupies  the  top  spot  with  27.5%.  In 
Slovakia, two channels reach more than 20%, the highest share being 28.7% for TV Joj. In Spain, 
Cuatro is the channel with the highest share, at 84.9%. The highest share obtained by a channel in 
Sweden is similarly high, with 83.1% for TV4. 

−  Comparing  with  the  figures  from  2020-2021,  the  share  of  domestic  works  has  increased  on  some 
channels, such as RTL Klub in Hungary rising from 4.8% to 42.4%, or Canale 5 in Italy increasing from 
24.8% to 66.9%. 

In the graph below, we present the share of time dedicated to domestic works out of the total time allotted to 
European and EU27 works. Concerning the share of domestic works within European works, Germany and 
Spain rank first with 75.7%. Domestic works represent over 50% of European works in three other Member 
States too: France, Poland and Italy. In 5 Member States, there are less than 30% of domestic works within 
European works: Estonia (10.2%), Austria (23.3%), Czechia (26.6%), Belgium (26.7%) and Slovakia (29.7%). 

Regarding the share of domestic works within EU works, there are a majority of Member States (8 in total) 
which  register  over  50%:  Germany  (80.4%),  Spain  (84.2%),  France  (83.8%),  Poland  (81.6%),  Italy  (74%), 
Denmark (66.6%), Hungary (62.7%) and Sweden (67.3%). In two Member States, the share of domestic works 
within EU27 works amounts to less than 30%: Estonia (16.2%) and Austria (25.3%).  

Figure 81. Share of domestic works as a percentage of European and EU27 works  

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5.1.8     Comparison with Member State data 

In this section, the study compares the percentages of European works, that we calculated based on the EPG 
and IMDb databases, with those reported by the Member States. The analysis was conducted on a channel-
by-channel basis in each Member State, as follows: 

−  Firstly, we identified the channels that were present both in our database and in the Member State 

reports. 

−  Secondly,  for  each  common  channel,  we  computed  the  difference  in  the  percentage  of  European 

works from our database and the one reported by the Member State. 

−  Thirdly, we calculated the average difference at the country level. In other words, we computed the 
average based on the difference in European works from each channel within a Member State. The 
results are presented in the second column of the table below.  

It  is  important  to  note  that  only  the  percentage  of  European  works  was  compared  with  the  Member  State 
reports and not the percentages of independent producers or recent works. The reason for this is that we have 
no information on the methodology used by Member States to calculate these two other indicators. In the case 
of independent producers, according to the Member State reports, this indicator should be calculated as the 
amount of European works made by independent producers as a percentage of total qualifying time. Based 
on this definition, the percentage of European works produced by independent producers is a sub-group of the 
European works. However, we found channels where the latter is higher than the former, which points to having 
used a different calculation method.  Concerning recent works, all Member States calculate this indicator as 
the amount of recent European works out of total European works made by independent producers only, which 
is different to our operationalisation. 

The following table shows the quotas reported by Member States on the share of European works. The figures 
from  the  table  are  calculated  as  the  average  share  of  European  works  among  the  reported  shares  at  the 
channel level. Only channels that were identified in both our database and in the Member State reports were 
used (as explained above): 

Member State 

EW works as reported by MS (%) 

AT 
BE 
CZ 
DE 

86.5 
70.5 
62.7 
73.5 

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DK 
EE 
ES 
FR 
HU 
IT 
NL 
PL 
RO 
SE 
SK 

82.9 
69.7 
72 
70.6 
91 
59 
68 
77 
76.8 
54.6 
69 

As the second step, we added the legal context in the analysis of European works, to further assess if the 
monitoring and verification systems in place, the number of employees allocated to verifying data or any other 
legal changes could correlate with fewer differences between our data and that of the Member States.  It is 
worth emphasizing that these elements are believed to be associated with minimizing the disparities between 
the  two  sets  of  data.  However,  it  is  important  to  acknowledge  that  these  elements  do  not  encompass  all 
possible factors that could account for these differences.  

The table below summarises this information:

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Table 43: Comparison of data from current study with data stemming from the Member State reports 

Member 
State 

Average 
difference 
EW342 

Number of 
channels 
matched 

MS data 
reported 

Current 
study data 

Legal changes 

Monitoring 
systems343 

Verification 
systems344 

Workforce 
streamlined345 

AT 

-63.9 

17 

2021  2022-2023 

BE 

-17.9 

31 

2021  2022-2023 

- Changes in 
legislation in 2021; 
reporting of data 
and percentages 
per programme 
must be made of a 
specific form and 
reasoning must be 
provided if the 
broadcaster does 
not comply with its 
obligations 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- No dedicated 
human resources 
to run verification 

- No dedicated 
human resources 
to run verification 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations + 
random checks 

- Verification 
system exists; a risk 
analysis is 
conducted and a 
detailed verification 
in case of 
discrepancies for 
the Flemish-
speaking 
community 

342 These numbers represent the differences expressed as an average percentage for each Member State comparing the share of European works (by aggregating the differences at the channel 
level) reported by Member States with the share of European works using the study’s methodology. The colours from this column have been formatted in the following way: the darker the colour 
(green or red), the higher the differences between the data from this study and that from the Member State reports.  

343 The colours from this column have been formatted in the following way: white/ no colour indicates that a basic monitoring system was put in place; green indicates that a stronger monitoring 
system was implemented while red indicates that a weaker monitoring system was implemented.  

344 The colours from this column have been formatted in the following way: white/ no colour indicates that a basic verification system was put in place; green indicates that a stronger verification 
system was implemented while red indicates that a weaker verification system was implemented. 

345 The colours from this column have been formatted in the following way: white/ no colour indicates that a limited number of employees were allocated to verifying the data, green indicates that a 
higher number of employees were allocated to verifying the data while red indicates that there is no dedicated human resource for running the verification. 

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Member 
State 

Average 
difference 
EW342 

Number of 
channels 
matched 

MS data 
reported 

Current 
study data 

Legal changes 

Monitoring 
systems343 

Verification 
systems344 

Workforce 
streamlined345 

CZ 

-36.3 

47 

2021  2022-2023 

DE 

8.4 

41 

2021  2022-2023 

DK 

-39.7 

1 

2021  2022-2023 

EE 

ES 

FR 

-47.7 

17 

2021  2022-2023 

-0.5 

28 

2021  2022-2023 

-34.0 

62 

2021  2022-2023 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations 

- Biennial report to 
competent 
authorities for 
public broadcasters 
'- Case-by-case 
reporting for 
comercial 
broadcasters 
- Biennial report to 
competent 
authorities 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations 

- Verification 
system exists and 
takes place by a 
sample-based check 

- At least 1 
dedicated 
employee 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- No dedicated 
human resources 
to run verification 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 
- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- Verification 
system exists and is 
conducted by 
external actors  

- No dedicated 
human resources 
to run verification 

-  10 or less 
dedicated 
employees 

-  10 or less 
dedicated 
employees 

- Verification 
system exists and is 
conducted by 
external actors  

-  10 or less 
dedicated 
employees 

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Member 
State 

Average 
difference 
EW342 

Number of 
channels 
matched 

MS data 
reported 

Current 
study data 

Legal changes 

Monitoring 
systems343 

Verification 
systems344 

Workforce 
streamlined345 

HU 

-67.2 

20 

2021  2022-2023 

IT 

-10.3 

45 

2021  2022-2023 

NL 

-44.7 

45 

2020  2022-2023 

PL 

-6.1 

39 

2021  2022-2023 

- Monthly reporting 
and annual 
examination 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations + 
random checks 
- Annual report to 
competent 
authorities for 
public broadcasters 
on the fulfilment of 
obligations 
- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations + 
random checks 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 
- Verification 
system exists and is 
conducted by 
external actors  

- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- No dedicated 
human resources 
to run verification 

- 10 or less 
dedicated 
employees 

- No dedicated 
human resources 
to run verification 

- At least 1 
dedicated 
employee 

- Changes in 
legislation in 2021 
competent 
authorities must 
send a report to the 
European 
Commission 
outlining the 
performance of 
broadcasters in 
fulfilling their 
obligations 

RO 

-54.6 

28 

2021  2022-2023 

- Twice a year 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- 10 or less 
dedicated 
employees 

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Member 
State 

Average 
difference 
EW342 

Number of 
channels 
matched 

MS data 
reported 

Current 
study data 

Legal changes 

Monitoring 
systems343 

Verification 
systems344 

Workforce 
streamlined345 

SE 

7.4 

19 

2021  2022-2023 

SK 

-46.4 

10 

2021  2022-2023 

- Annual report to 
competent 
authorities on the 
fulfilment of 
obligations 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- 10 or less 
dedicated 
employees (15% 
of workforce 
streamlined) 

- Changes in 
legislation in 2020; 
periodicity changed 
to annually and 
introduced a 
specific digital form 
through which the 
reporting must take 
place 

- Case-by-case 
reporting 

- Verification 
system exists but 
no specific 
procedural rules on 
the process 

- No dedicated 
human resources 
to run verification 

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The second column of the table shows the average difference in the percentage of European works. Values 
that are closer to zero indicate fewer differences between the data from this study and that stemming from the 
Member State reports. Thus, Member States with average differences farther away from zero are those where 
the highest differences were found concerning the percentage of European works.  

Overall, the main findings based on the table above are the following: 

•  The highest differences were found in Hungary, Austria, and Romania (an average difference of over 

50%) 

o 

o 

o 

In Hungary, 20 common channels were found between our data and that of the Member States 

In Austria, 17 common channels were identified 

In Romania, 28 common channels were identified 

•  The  lowest  differences  were  found  in  Spain,  Germany,  Italy,  Poland  and  Sweden  (an  average 

difference of less than or around 10%) 

o 

o 

o 

o 

o 

In Spain, 28 common channels were found between our data and that of the Member States 

In Germany, 41 common channels were identified 

In Italy, 45 common channels were identified 

In Poland, 39 common channels were identified 

In Sweden, 19 common channels were identified. 

This analysis could be conducted in all Member States except for Denmark, where the percentage of European 
works was not available in nearly any channel from the Member State report.  

The differences in the percentage of European works could be the result of various factors. Firstly, the data 
from  the  current  study  takes  into  account  a  significant  amount  of  datawhen  calculating  the  percentage  of 
European works (3 full months of TV programmes broadcasted) while the exact sample sizes used by Member 
States  are  not  known.  Member  States  report  the  share  of  European  works  at  the  channel  level.  There  is 
however no detailed information on whether Member States consider all the works broadcast to calculate these 
shares or if a limited sample is always used. If Member States have varying approached in determining the 
share of European works, such as different sample sizes or considering different subsets of works, it introduces 
a significant factor of inconsistency. It is therefore crucial to have detailed information about the methodology 
used, including whether it involves all works or a representative sample. Secondly, the difference could also 
be explained by  the methodology used to identify and calculate qualifying time and European works. The way 
qualifying time was defined in the current study is any time allotted to programmes excluding news, sports 
events,  games,  advertising,  teletext  services  and  teleshopping.  Subsequently,  to  classify  a  production  as 
European, we used the countries of origin which were found either by accessing publicly available databases 
or by retrieving them directly from the EPG data, when available. It is still uncertain how European works were 
identified in the individual Member States, which have different methods. In the current study, we considered 
a European work as any work that originates or has the majority of the production companies originating in 
Member States or in countries party to the European Convention on Transfrontier Television of the Council of 
Europe. Thirdly, another reason for observing these differences could be related to the fact that the current 
study uses data collected between November 2022 to January 2023, while the data from the Member State 
reports are from 2021. Finally, the differences could also arise from the fact that identifying European works 
from the qualifying works relies on retrieving the countries of origin of the works gathered from the EPG data. 
Although substantial efforts were put into identifying the countries of origin for most works, this was not possible 
in some cases. This shortcoming was explained in more detail in the methodological part of Volume 3.  

Moreover, as explained above too, we added in the table the legal information regarding the monitoring and 
verification systems implemented, the number of employees allocated to verifying the data and any relevant 
legal changes identified..  

The main objective  of this  analysis is to understand  if having stricter processes in place  can contribute   to 
fewer  differences  between  the  data  from  this  study  and  that  of  the  Member  States.  We  could  identify  the 
following patterns: 

•  The highest differences are observed in these Member States where there is a verification system in 

place but no specific procedural rules on the process. 

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•  The lowest differences are observed in the Member States which have at least one of the following: 

o  Annual reports, coupled with random checks on the quota fulfilment 

o  Clearer  rules  on  the  way  data  are  verified  such  as  in  Belgium  where  a  risk  analysis  is 

conducted 

o  Having a verification system where external actors verify the data leads to significantly fewer 

discrepancies between the data in this study and that of the Member States 

o  Member States with teams composed of more employees responsible for verifying the data 

have fewer differences.  

Germany is the only exemption, as it has a less strict monitoring and verification system, and no dedicated 
human resources to run the verification of data, but the differences between our data and that from the Member 
State report are low.  

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5.2     Non-linear service content analysis 

The  purpose  of  this  task  is  to  analyse  the  content  provided  by  VoD  services.  This  analysis  distinguishes 
between catalogue composition and the methods used to ensure prominence of European works, which was 
based primarily on the mystery shopping exercise. The final sample was built from a dataset of VoD catalogues 
of  310  services  which  encompassed  over  1  700  catalogues  across  39  countries.  The  final  analysis  was 
conducted based on 21 EU Member States and Norway and covers: 

‒ 

‒ 

the number of titles offered and their genre, distinguished into European works, EU27 works and UK 
works. 

further identification and exploration of the number of European works produced by independent 
producers. 

‒  coverage of recent works; and  

‒  domestics or quasi-domestic European Works versus European Works produced in other countries. In 

other words, these are the Europeans works which were produced or co-produced by the target 
(analysed) country versus those from other countries.   

5.2.1     Summary of the methodology 

For this task, we explored multiple sources of data. However, eventually we purchased an extract from the 
dataset from JustWatch.  

JustWatch is a video-streaming aggregator which compiles data about catalogues of VoD services combining 
SVoD, TVoD and some FVoD. JustWatch is the aggregator with largest number of catalogues.  

JustWatch was briefed and instructed to carry out the following data extractions from their database:  

‒  Per service and per target country, provide:  

‒  The total number of productions – disaggregated by movies and series whereby each season of a 

series is treated as a unique production;  

‒  The total number of European and non-European productions in each category (series/ movies). 

JustWatch was instructed to consider as “European” all productions or co-productions featuring at 
least one of the European countries as per AVMSD scope of application;  

‒  Disaggregate the data by genre: the genres provided are those available in the JustWach database;  

‒  Disaggregate the data by recent works (less than five years) and non-recent works; 

‒  Disaggregate the data by independent productions. For this analysis a work was considered as 

independent if at least one of its production companies was independent. 

During the  previous study  conducted  in 2020-2021, the  feasibility of identifying  independent  productions  in 
JustWatch catalogues was limited to series. The reason for this was that for movies, the database of JustWatch 
does not list the name of the production companies. It was not possible to match this data with a list of major 
or independent production companies. Such matching was possible for series. However, series represent only 
a minor share of the catalogues given the fact that one season is only counted as one production. 

For  the  current  study,  however,  Kantar  Public  received  from  JustWatch  the  full  list  of  movies  from  their 
database  which  were  then  matched  against  the  IMDb  database  to  retrieve  the  names  of  the  production 
companies. The process was very complex as it implied using our bespoke web-grabber tool to retrieve the 
names of the production companies for over 60 000 movies. The outcome was very positive as we managed 
to retrieve the names of the production companies for over 80% of the movies from JustWatch’s database. 
This way, the calculation of the share of European independent productions is robust as it is based on most of 
the productions part of the catalogues tracked by JustWatch. 

‒  Disaggregate the data by domestic and non-domestic European works. Whereby domestic European 
works are works which are made available in the targeted (analysed) country and for which at least 
one of the co-production companies originates in that country too (home country). Non-domestic 
European works do not include the targeted country as part of the production companies.   

‒  Per target country provide:  

‒  The top 10 countries that feature in all the (co-)productions across all catalogues targeting a given 

country; 

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‒  The number of productions which involve a given top 10 country.  

The extractions were made in February 2023. Therefore, the data presented in this analysis is the latest one.  

One important mention is that, although the dataset received from JustWatch covers 25 EU Member States 
(+14 additional non-EU countries), all the tables presented in this section are based on the data stemming 
from 21 Member States + Norway. The first table below shows the specific countries selected. The reason why 
this  sample  was  chosen  is  because  we  aimed  to  keep  in  the  current  analysis  only  the  countries  that  were 
analysed in the previous (2020-2021) study too and therefore highlight the key differences according to each 
indicator. The data for the other countries (both EU Member States and non-EU countries) are presented in 
the Annex.  

Importantly, the current study covers additional indicators too, compared to the previous one, which reflected 
data from 2020-2021. These indicators have been calculated by Kantar Public after receiving the micro-data 
(title-level data) from JustWatch. An Excel file for each of the 39 countries were sent to Kantar which contained 
the titles from each VoD service and their corresponding countries of origin.  

Specifically, the following are the additional indicators calculated: 

•  The  total  number  of  European  works  by  country  where  a  European  work  was  defined  differently 
compared to the indicator above. For this indicator, a European work was defined as any production 
whose majority of the production companies were European (i.e., over 50% of them); 

•  The total number of EU works by country where an EU work was defined as any production which had 

at least one production company originating in an EU Member State; 

•  The total number of EU works by country where an EU work was defined differently too, specifically 
as  any  production  which  had  the  majority  of  the  production  companies  originating  in  EU  Member 
States; 

•  The total number of UK works by country where an UK work was defined as any production which had 

at least one production company originating in the UK. 

5.2.2     Services covered per country 

Caveat: The data presented in this section is analysed by the target market country and not by country of 
jurisdiction, unless otherwise specified. By target market country (or targeted country), we mean the country/ 
market  where  the  catalogue  is  made  available.  For  example,  the  content  of  the  Netflix  catalogues  is 
analysed  based  on  the  countries  where  they  are  made  available  rather  than  considering  the  country  of 
jurisdiction  for  the  service.  So,  Netflix  Germany  is  analysed  under  Germany  and  Netflix  France  under 
France. 

There are important differences in the share of European works by VoD service providers in the case of 
multi-country providers. This is mainly due to the market specificities and the audience demand. 

In  total,  1  722  VoD  services  across  39  targeted  countries  (25  EU  Member  States 346and  Andorra,  Albania, 
Bosnia and Herzegovina, Switzerland, The United Kingdom, Iceland, Liechtenstein, Monaco, Moldova, North 
Macedonia, Seria, San Marino, Turkey and Norway) are included in the dataset received from JustWatch, an 
increase of 971 services from 2021 (Table 44). The 39 countries are those that are available in the JustWatch 
dataset; therefore, no criteria other than the availability of data were used for the selection. The number of 
catalogues per country is shown below for the selected 21 Member States and Norway. This analysis includes 
all the major VoD providers in each country and many other smaller services. 

The full list is provided in Annex 5.  

346 CY and LU are the two EU Member States that are not covered by the JustWatch database. 

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Table 44: Number of services covered in this analysis (2021 and 2023 comparison) 

Country  

Austria 

Belgium 

Bulgaria 

Czechia 

Germany 

Denmark 

Estonia 

Spain 

Finland 

France 

Greece 

No of 
services 
(2021) 

No of 
services 
(2023) 

Difference   Country 

No of 
services 
(2021) 

No of 
services 
(2023) 

Difference 

50 

31 

22 

22 

80 

36 

24 

38 

37 

50 

20 

79 

42 

30 

30 

119 

50 

30 

65 

50 

78 

26 

29 

11 

8 

8 

39 

14 

6 

27 

13 

28 

6 

Hungary 

Ireland 

Italy 

Lithuania 

Latvia 

24 

36 

38 

25 

24 

Netherlands  40 

Norway 

Poland 

Portugal 

Romania 

Sweden 

38 

28 

28 

19 

41 

31 

45 

63 

31 

30 

56 

51 

40 

36 

26 

54 

7 

9 

25 

6 

6 

16 

13 

12 

8 

7 

13 

Source: JustWatch 

1 914 406  productions were included  in the analysis  across all  the catalogues  included  in  the analysis, an 
increase of 46% from 2021 (1 315 520). This figure does not represent the number of unique productions, as 
many productions are in multiple catalogues. The vast majority of these productions are movies (87.6%), while 
TV series represent 12.4% of the sample.  

As shown below in Table 45, the countries with the biggest catalogues, in terms of the number of productions, 
are Germany (12% of total productions), Finland (9%), and Austria (8%). This trend remains unchanged from 
the 2021 figures. Five countries347 experienced a marginal growth in their relative share of total productions 
(between  1%  and 4% percentage  points), while 13 countries348 experienced  no change between  2021  and 
2023. The share of total production decreased in Ireland (-1 pp), Austria (-3 pp), Germany (-3 pp), and France 
(-7 pp).  

Table 45: Number of productions included in the analysis – per country 

Country  No of 

productions 
(2021) 

No of 
productions 
(2023) 

Difference 

Share of total 
(2021) 

Share of total 
(2023) 

Difference 

AT 

BE 

BG 

CZ 

139 700  

159 983  

20 283  

11% 

47 460  

71 901  

24 441  

24 664  

41 682  

17 018  

27 534  

45 579  

18 045  

4% 

2% 

2% 

8% 

4% 

2% 

2% 

-3% 

0% 

0% 

0% 

347 Finland (4% percentage point increase), Greece (3% pp), Netherlands (2% pp), Spain (2% pp), and Sweden (1% pp) 

348 Hungary, Italy, Czechia, Romania, Lithuania, Estonia, Poland, Denmark, Latvia, Bulgaria, Portugal, Belgium, and Norway 

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Country  No of 

productions 
(2021) 

No of 
productions 
(2023) 

Difference 

Share of total 
(2021) 

Share of total 
(2023) 

Difference 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

NL 

NO 

PL 

PT 

RO 

ES 

SE 

190 890  

224 553  

33 663  

15% 

12% 

-3% 

60 519  

100 899  

40 380  

28 437  

44 332  

15 895  

24 614  

97 255  

72 641  

58 989  

111 892  

52 903  

5% 

2% 

2% 

4% 

61 345  

170 086  

 108 741  

5% 

120 156  

39 335  

-80 821  

30 378  

46 723  

16 345  

93 542  

116 572  

23 030  

70 572  

103 244  

32 672  

28 203  

44 338  

16 135  

27 237  

41 782  

14 545  

45 242  

94 044  

48 802  

72 504  

106 174  

33 670  

44 723  

62 786  

18 063  

37 230  

54 783  

17 553  

13 325  

26 049  

12 724  

68 256  

110 414  

42 158  

9% 

2% 

7% 

5% 

2% 

2% 

3% 

6% 

3% 

3% 

1% 

5% 

5% 

2% 

5% 

6% 

9% 

2% 

2% 

6% 

5% 

2% 

2% 

5% 

6% 

3% 

3% 

1% 

6% 

0% 

0% 

3% 

2% 

4% 

-7% 

0% 

-1% 

0% 

0% 

0% 

2% 

0% 

0% 

0% 

0% 

1% 

TOTAL 

1 315 520  

1 914 406  

598 886  

Source: JustWatch 

Table 46 compares the top 5-7 services per country in terms of number of productions in the catalogue across 
2021 and 2023. The number of productions is calculated as the sum of: 

‒  Movies/films, and  

‒  Season series, whereby each season is counted as one production. 

Table  46:  Top  five  to  seven  services 349 included  in  the  analysis  by  number  of  productions  in  the 
catalogue (by target country) 
Services 

Difference 

No* (2021) 

No* (2023) 

Country  

Austria 

Amazon Video 

Apple iTunes 

24 911 

                  31 029  

                    6 118  

18 136 

 -  

- 

349 The table includes those services with the highest number of productions. When the number of productions between 5th and 6th 
service was similar, both were included. 

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Country  

Services 

No* (2021) 

No* (2023) 

Difference 

maxdome Store 

14 294 

                  11 359  

-                   2 935  

Google Play Movies 

14 283 

                  17 813  

                    3 530  

7 647 

                    6 225   -                   1 422  

6 525 

                    7 624  

                    1 099  

- 

- 

                    6 928  

                  20 954  

Belgium 

Apple iTunes 

15 755 

- 

Google Play Movies 

9 924 

                  22 437  

                  12 513  

Netflix 

4 419 

                    6 631  

                    2 212  

Amazon Prime Video 

3 276 

                    3 724  

                       448  

3 265 

                    3 950  

                       685  

Chili 

Rakuten TV 

Netflix 

Apple TV 

Rakuten TV 

Sooner 

Sun Nxt 

Apple TV 

Bulgaria 

Apple iTunes 

8 513 

 -  

Czechia 

Germany 

Netflix 

Zee5 

DocAlliance Films 

HBO Go 

Apple TV 

Sun Nxt 

Disney Plus 

HBO Max 

Apple iTunes 

Google Play Movies 

Netflix 

O2 TV 

DocAlliance Films 

Sun Nxt 

HBO Max 

Disney Plus 

Apple TV 

Amazon Video 

Apple iTunes 

Google Play Movies 

YouTube 

maxdome Store 

EntertainTV 

MagentaTV 

Rakuten TV 

Apple TV 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

 -  

                    4 168  

                    2 857  

                  21 413  

6 015 

                    7 933  

2 369 

                    2 128  

1 323 

                    1 524  

1 048 

 -  

                  14 508  

                    2 857  

                    2 284  

                    1 835  

11 444 

- 

4 828 

                    5 314  

                       486  

3 220 

                    6 527  

                    3 307  

1 171 

- 

 -  

1 170 

                    1 881  

                       711  

                    2 857  

                    1 979  

                    1 817  

                  15 730  

 -  

 -  

 -  

- 

29 233 

                  31 028  

                    1 795  

19 670 

- 

- 

16 589 

                  18 757  

                    2 168  

15 376 

                  17 178  

                    1 802  

14 297 

                  11 457   -                   2 840  

13 527 

 -  

                  15 111  

                    7 752  

                  22 437  

- 

- 

- 

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

- 

 -  

 -  

 -  

 -  

 -  

Denmark 

Apple iTunes 

13 179 

 -  

Google Play Movies 

10 024 

                  11 141  

                    1 117  

223 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country  

Services 

Blockbuster 

No* (2021) 

No* (2023) 

Difference 

8 457 

                    9 414  

                       957  

Amazon Prime Video 

4 654 

 -  

 -  

Estonia 

Spain 

Finland 

France 

Netflix 

SF Anytime 

Viaplay 

Rakuten TV 

Apple TV 

Apple iTunes 

Netflix 

Google Play Movies 

DocAlliance Films 

Mubi 

GuideDoc 

Sun Nxt 

Disney Plus 

Apple TV 

Filmin 

Apple iTunes 

 -  

 -  

 -  

 -  

 -  

 -  

 -  

4 126 

                    6 428  

                    2 302  

                  11 772  

                    7 331  

                    4 779  

                  18 690  

10 734 

 -  

 -  

 -  

 -  

 -  

5 720 

                    7 753  

                    2 033  

4 218 

                    4 539  

                       321  

1 275 

                    1 521  

                       246  

942 

 -  

 -  

783 

                       960  

                       177  

                    2 857  

                    2 304  

                  16 057  

 -  

 -  

 -  

8 414 

                    9 165  

                       751  

8 158 

-                   8 158  

Google Play Movies 

6 215 

                    6 847  

                       632  

Rakuten TV 

5 840 

                    6 802  

                       962  

Amazon Prime Video 

4 694 

 -  

 -  

Netflix 

Netflix basic with Ads 

Amazon Video 

Apple TV 

Apple iTunes 

4 499 

                    7 034  

                    2 535  

 -  

 -  

 -  

                    6 677  

                    6 727  

                    9 728  

13 549 

 -  

 -  

 -  

 -  

 -  

Google Play Movies 

9 453 

                  10 494  

                    1 041  

Blockbuster 

7 385 

                    8 616  

                    1 231  

Amazon Prime Video 

4 526 

 -  

Netflix 

SF Anytime 

Telia Play 

Viaplay 

Apple TV 

Apple iTunes 

Orange VoD 

4 100 

                    6 500  

 -  

 -  

 -  

 -  

                  10 997  

                  10 418  

                    7 436  

                  18 812  

15 764 

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

11 971 

                  12 639  

                       668  

Google Play Movies 

11 096 

                  12 290  

                    1 194  

YouTube 

Canal VoD 

Universcine 

Microsoft Store 

Amazon Video 

Apple TV 

10 784 

                  11 858  

                    1 074  

9 794 

                  11 118  

                    1 324  

7 837 

                  10 493  

                    2 656  

5 681 

 -  

 -  

 -  

                  11 848  

                  18 830  

 -  

 -  

224 

 
 
  
  
  
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country  

Greece 

Services 

Apple iTunes 

No* (2021) 

No* (2023) 

Difference 

10 386 

 -  

 -  

Google Play Movies 

4 351 

                    4 808  

                       457  

Netflix 

3 873 

                    6 820  

                    2 947  

DocAlliance Films 

1 204 

                    1 527  

                       323  

Hungary 

Mubi 

Sun Nxt 

Disney Plus 

Filmzie 

Apple TV 

Apple iTunes 

YouTube 

990 

 -  

 -  

 -  

 -  

 -  

                    2 857  

                    1 558  

                       897  

                  14 699  

                 9 830 

 -  

                  4 348 

                    4 698  

Google Play Movies 

                 4 304                       4 660  

Netflix 

Horizon 

HBO Go 

Sun Nxt 

HBO Max 

Disney Plus 

Apple TV 

             2 910                       7 035  

                 1 760  

                 1 232  

 -  

 -  

 -  

 -  

 -  

 -  

                    2 857  

                    1 877  

                    1 835  

                  13 971  

Ireland 

Apple iTunes 

                21 208  

 -  

Google Play Movies 

                18 640                     20 403  

Amazon Prime Video 

                10 563                       9 529  

Italy 

Lithuania 

Sky Store 

Netflix 

Rakuten TV 

Microsoft Store 

Apple TV 

Sky Go 

Chili 

                  9 274                     11 409  

                 6 351                       7 100  

                 6 224                       7 725  

 -  

 -  

 -  

 -  

                  29 729  

                    3 667  

                 10 653  

                    8 040  

Apple iTunes 

                   9 363  

 -  

Google Play Movies 

                   8 430  

                    9 607  

Amazon Prime Video 

                   5 689  

 -  

Rakuten TV 

                   5 390  

                    6 721  

Apple TV 

Netflix 

Netflix basic with Ads 

Amazon Video 

Apple iTunes 

Netflix 

 -  

                  11 974  

                   4 629  

                    6 934  

                    2 305  

 -  

 -  

                    6 597  

                    9 740  

                   9 562  

 -  

                   5 723  

                    7 679  

 -  

 -  

 -  

Google Play Movies 

                   4 004  

                    4 316  

DocAlliance Films 

                   1 253  

                    1 523  

Telia Play 

Sun Nxt 

                   1 176  

                    1 650  

 -  

                    2 857  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

350 

356 

4 125 

1 763 

-1 034 

2 135 

749 

1 501 

-2 613 

1 177 

1 956 

312 

270 

474 

225 

 
 
  
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country  

Services 

Disney Plus 

Apple TV 

No* (2021) 

No* (2023) 

Difference 

 -  

 -  

                    2 304  

                  14 706  

Latvia 

Apple iTunes 

                   9 629  

 -  

Netflix 

                   5 715  

                    7 763  

Google Play Movies 

                   4 178  

                    4 485  

DocAlliance Films 

                   1 225  

                    1 526  

Mubi 

Sun Nxt 

GuideDoc 

Disney Plus 

Apple TV 

                      947  

 -  

 -  

 -  

 -  

 -  

                    2 857  

                       960  

                    2 304  

                  13 695  

Netherlands 

Apple iTunes 

                   9 529  

 -  

Norway 

Google Play Movies 

                   8 148  

                    8 925  

Netflix 

KPN 

                   4 536  

                    5 176  

                   3 141  

                    4 350  

Rakuten TV 

                   3 027  

 -  

Microsoft Store 

Amazon Video 

Pathe Thuis 

Apple TV 

Apple iTunes 

Strim 

 -  

 -  

 -  

 -  

                  17 294  

                    7 213  

                    4 902  

                  11 501  

                 13 059  

                 10 853  

 -  

 -  

Google Play Movies 

                   9 846  

                  10 922  

Blockbuster 

                   7 656  

                    8 734  

Amazon Prime Video 

                   4 626  

 -  

SF Anytime 

Viaplay 

Netflix 

Rakuten TV 

Apple TV 

 -  

 -  

 -  

 -  

 -  

                  11 646  

                    7 369  

                    6 202  

                    4 800  

                  18 491  

Poland 

Apple iTunes 

                 10 825  

 -  

Google Play Movies 

                   4 078  

                    4 358  

Chili 

Horizon 

Apple TV 

Sun Nxt 

                   4 068  

                    3 703  

 -  

 -  

 -  

                    6 024  

                  14 923  

                    2 857  

Portugal 

Apple iTunes 

                   9 120  

 -  

Netflix 

YouTube 

                   4 163  

                    7 088  

                   4 122  

                    4 360  

Google Play Movies 

                   4 077  

                    4 319  

Meo 

Rakuten TV 

                   3 784  

                    3 796  

2 048 

307 

301 

777 

640 

1 209 

1 076 

1 078 

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

280 

-365 

2 925 

238 

242 

12 

Netflix 

YouTube 

                   4 579  

                    6 202  

1 623 

                   4 121  

                    4 397  

                       276  

 -  

                    3 277  

 -  

226 

 
 
  
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country  

Romania 

Services 

Sun Nxt 

Apple TV 

Netflix 

Horizon 

No* (2021) 

No* (2023) 

Difference 

 -  

 -  

                    2 857  

                  12 670  

                   4 445  

                    7 395  

                   2 150  

DocAlliance Films 

                   1 325  

                    1 527  

Mubi 

HBO Go 

Sun Nxt 

HBO Max 

Disney Plus 

Filmzie 

                   1 005  

                      864  

 -  

 -  

 -  

 -  

 -  

 -  

                    2 857  

                    1 869  

                    1 849  

                       931  

Sweden 

Apple iTunes 

                 14 465  

 -  

Google Play Movies 

                   9 931  

                  10 946  

Blockbuster 

                   7 816  

                    9 006  

Amazon Prime Video 

                   4 673  

 -  

Netflix 

SF Anytime 

Viaplay 

Rakuten TV 

 Apple TV  

                   4 125  

                    6 417  

 -  

 -  

 -  

 -  

                  12 646  

                    7 465  

                    4 943  

                  19 815  

*Number of productions in the catalogue analysed. 
Source: JustWatch 

5.2.3     European works in VoD catalogues 

2 950 

-2 150 

202 

1 015 

1 190 

2 292 

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

 -  

As explained above, the JustWatch database analysed contained 2 788 534 productions across 1 722 services 
in 26 EU Member States and 13 non-EU Member States, in February 2023. Of all these countries, we present 
the analysis based on 21 EU Member States and Norway as these were present in the previous (2020-2021) 
study  too.  Note  that  these  are  not  unique  productions,  but  the  total  count  of  all  productions  across  all  the 
services analysed. This means that a given production featured in 10 different services is counted 10 times.  

The following analysis considers the following definitions: 

‒  European works: European productions + European co-productions where European co-productions 

were defined as any production where there are at least two production companies and at least one of 
them is European 

‒  European works2: European productions + European co-productions where European co-productions 
were defined as any production where there are at least two production companies and the majority of 
them are European 

‒  EU27 works: EU productions + EU co-productions where EU co-productions were defined as any 

production where there are at least two production companies and at least one of them is from an EU 
Member State 

‒  EU27 works2: EU productions + EU co-productions where EU co-productions were defined as any 

production where there are at least two production companies and the majority of them are from an EU 
Member States 

‒  UK works: any title which has at least one production company originating in the UK.  

Table 47:Table 47 compares the share of European works (both definitions), EU27 works (both definitions), 
and UK works relative to total productions. 

227 

 
 
  
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Annex 6 contains the detailed tables with more information about the number of movies and series per 
conceptualisation. 

In  summary,  European  works  represent  on  average  35%  of  the  catalogues  included  in  the  sample  and 
analysed according to the first definition, whereas European works represent 27% of the catalogues analysed 
according to the second definition. Similarly, EU27 works represent 24% of the catalogues analysed according 
to the first definition, whereas EU27 works represent 18% of the catalogues analysed according to the second 
definition. Finally, UK works represent 11% of the catalogues analysed across all the services listed. 

Table 47: Share of European works, EU27 works, and UK works (2023) 

Country  

 All 
productions  

Share of 
European 
Works  

Share of 
European 
Works 2  

Share of EU 
Works  

Share of EU 
Works 2  

Share of UK 
Works  

 AT  

 BE  

 BG  

 CZ  

 DE  

 DK  

 EE  

 ES  

 FI  

 FR  

 GR  

 HU  

 IE  

 IT  

 LT  

 LV  

 NL  

 NO  

 PL  

 PT  

 RO  

 SE  

159 983  

  71 901  

  41 682  

  45 579  

224 553  

100 899  

  44 332  

  97 255  

111 892  

170 086  

  39 335  

  46 723  

116 572  

103 244  

  44 338  

  41 782  

  94 044  

106 174  

  62 786  

  54 783  

  26 049  

110 414  

 Total  

1 914 406  

Source: JustWatch 

43% 

40% 

29% 

31% 

44% 

37% 

29% 

40% 

35% 

48% 

28% 

27% 

32% 

41% 

30% 

30% 

36% 

36% 

31% 

30% 

35% 

37% 

35% 

35% 

32% 

23% 

24% 

36% 

29% 

23% 

32% 

26% 

40% 

22% 

20% 

24% 

33% 

23% 

24% 

27% 

28% 

23% 

22% 

29% 

28% 

27% 

33% 

31% 

19% 

20% 

34% 

26% 

19% 

30% 

24% 

40% 

18% 

17% 

17% 

32% 

19% 

19% 

25% 

22% 

20% 

20% 

25% 

26% 

24% 

25% 

24% 

14% 

15% 

27% 

19% 

14% 

23% 

16% 

31% 

13% 

12% 

11% 

25% 

14% 

14% 

18% 

15% 

15% 

14% 

20% 

18% 

18% 

11% 

10% 

9% 

10% 

11% 

13% 

10% 

11% 

13% 

10% 

10% 

10% 

16% 

11% 

10% 

10% 

12% 

13% 

10% 

11% 

10% 

13% 

11% 

Comparing the share of European works in VoD catalogues between 2021 and 2023 

European  works,  where  any  of  the  production  companies  are  European,  represent  35%  of  the  catalogues 
analysed in the sample across all the services listed, an increase of 2% percentage points compared to the 
2020-2021 figure.  

Table 47 compares the share of European works relative to total productions per targeted country between 
the current (2023) and previous (2020-2021) monitoring period. In 2023, the share of European works differs 
across  targeted  countries  from  27%  in  Hungary  (1  percentage  point  increase  from  2020-2021)  to  48%  in 
France (no change). On the one hand, Finland, Portugal, Estonia, and Latvia experienced the largest increase 
in their share of European works (+4 pp each). On the other hand, Romania experienced the largest decrease 
(from 36% to 35%).

228 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 47: European works as share of total productions – per country 

Country 

All 
production
s (2021) 

All 
production
s (2023) 

Difference 

All 
European 
movies 
(2021) 

All 
European 
movies 
(2023) 

Difference 

All 
European 
series 
(2021) 

All 
European 
series 
(2023) 

Difference 

Share of 
European 
works 
(2021) 

Share of 
European 
works 
(2023) 

Difference 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

EL 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

139 700  159 983  

 20 283  

47 460 

  71 901  

 24 441  

24 664 

  41 682  

 17 018  

27 534 

  45 579  

 18 045  

190 895  224 553  

 33 658  

60 519  100 899  

 40 380  

28 437 

  44 332  

 15 895  

58 989 

  97 255  

 38 266  

61 345  111 892  

 50 547  

120 156  170 086  

 49 930  

24 614 

  39 335  

 14 721  

30 378 

  46 723  

 16 345  

93 542  116 572  

 23 030  

70 573  103 244  

 32 671  

28 203 

  44 338  

 16 135  

27 237 

  41 782  

 14 545  

45 242 

  94 044  

 48 802  

72 504  106 174  

 33 670  

44 723 

  62 786  

 18 063  

37 230 

  54 783  

 17 553  

13 325 

  26 049  

 12 724  

54 902 

16 681 

5 787 

7 273 

74 372 

19 258 

6 629 

20 928 

17 517 

55 168 

5 841 

7 307 

24 047 

26 122 

6 965 

6 538 

13 692 

22 274 

13 039 

9 164 

4 146 

62 659 

27 222 

10 855 

12 939 

89 901 

34 644 

11 724 

35 759 

36 548 

76 361 

10 175 

11 777 

32 383 

39 269 

12 095 

11 330 

30 845 

34 503 

17 081 

15 179 

8 009 

7 757 

10 541 

5 068 

5 666 

15 529 

15 386 

5 095 

14 831 

19 031 

21 193 

4 334 

4 470 

8 336 

4 210  5 771  

958  1 489  

606  1 034  

563  1 039  

7 279  9 341  

1 419  3 177  

589  1 044  

1 568  3 283  

1 367  2 838  

2 874  5 365  

434 

   808  

661 

   955  

2 666  4 382  

13 147 

1 344  2 956  

5 130 

4 792 

17 153 

12 229 

4 042 

6 015 

3 863 

634  1 098  

582  1 040  

1 797  2 769  

2 002  4 223  

1 034  2 114  

634  1 274  

593  1 061  

68 256  110 414  

 42 158  

21 335 

37 669 

16 334 

1 798  3 235  

1 561  

   531  

   428  

   476  

2 062  

1 758  

   455  

1 715  

1 471  

2 491  

   374  

   294  

1 716  

1 612  

   464  

   458  

   972  

2 221  

1 080  

   640  

   468  

1 437  

TOTAL 

1 315 526  1 914 406  

  598 880  

438 985 

658 927 

219 942 

35 612  60 296  

24 684  

Source: JustWatch

42% 

37% 

26% 

28% 

43% 

34% 

25% 

38% 

31% 

48% 

25% 

26% 

29% 

39% 

27% 

26% 

34% 

33% 

31% 

26% 

36% 

34% 

36% 

43% 

40% 

29% 

31% 

44% 

37% 

29% 

40% 

35% 

48% 

28% 

27% 

32% 

41% 

30% 

30% 

36% 

36% 

31% 

30% 

35% 

37% 

38% 

+1% 

+3% 

+3% 

+3% 

+1% 

+3% 

+4% 

+2% 

+4% 

+0% 

+3% 

+1% 

+3% 

+2% 

+3% 

+4% 

+2% 

+3% 

+0% 

+4% 

-1% 

+3% 

+2% 

229 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

The tables that follow compare the share of European works (both definitions), EU27 works (both definitions), 
and UK works per country catalogue for the largest four VoD service providers in the current reporting period 
(2023). There are  notable  differences in the share of  the different  indicators in the catalogues of  the same 
service depending on the target country. 

Table  49Table  49 presents the share of European works, EU27 works, and UK  works in the catalogues of 
Netflix per targeted country. The Netflix catalogue has the highest share of the different categories of European 
works in Czechia, Romania, Greece, and Hungary. On the other hand, the Netflix catalogue has the lowest 
shares in Ireland in both indicators of European and EU works, but not for the UK works indicator. The Netflix 
catalogue has the lowest share of UK works in Germany. 

As shown in Table 48, the Amazon Prime Video catalogue has the highest share of the different indicators in 
Italy, Austria, and Germany. On the other hand, the Amazon Prime Video catalogue has the lowest shares in 
Ireland in all indicators, except for the UK works indicator. The Amazon Prime Video catalogue has the lowest 
share of UK works in Belgium, Poland, Austria, Germany, and France. 

As shown in Table 49, the Apple TV catalogue has the share of the different indicators in France, Germany, 
and Italy, except the UK works indicator. On the other hand, the Apple TV catalogue has the lowest shares in 
Portugal across all the indicators, except for the UK works indicator. According to the UK works indicator, the 
Apple TV catalogue has the highest share in Ireland and the lowest share in Czechia, Belgium, Poland, and 
Greece. 

All  the  Mubi  catalogues  analysed  contain  well  above  40%  of  European  works  (both  definitions)  and  EU27 
works (first definition) (Table 50). In contrast, according to the second definition, the Mubi catalogues analysed 
contain above 30% of EU27 works and between 6% and 11% of UK works. 

230 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 49: Share of European works, EU27 works, and UK works in the catalogues of Netflix per targeted country (2023) 
% of EU Works 2 

% of European Works  % of European Works 

% of EU Works 

Name of VoD 
Provider 

Targeted 
Country 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Source: JustWatch 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

2 

41% 

39% 

44% 

52% 

41% 

42% 

44% 

44% 

43% 

38% 

46% 

46% 

35% 

43% 

44% 

44% 

44% 

44% 

42% 

45% 

48% 

42% 

36% 

34% 

40% 

47% 

37% 

37% 

40% 

40% 

38% 

34% 

42% 

41% 

30% 

38% 

40% 

40% 

38% 

39% 

37% 

41% 

43% 

38% 

31% 

29% 

30% 

37% 

31% 

29% 

30% 

32% 

30% 

29% 

33% 

33% 

24% 

30% 

30% 

30% 

30% 

31% 

31% 

32% 

33% 

30% 

% of UK Works 

27% 

24% 

26% 

33% 

27% 

25% 

27% 

28% 

26% 

25% 

29% 

28% 

20% 

26% 

27% 

27% 

26% 

27% 

27% 

28% 

29% 

26% 

8% 

9% 

12% 

13% 

8% 

12% 

12% 

11% 

12% 

8% 

12% 

12% 

10% 

12% 

12% 

12% 

12% 

12% 

9% 

12% 

13% 

11% 

231 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 48: Share of European works, EU27 works, and UK works in the catalogues of Amazon Prime Video per targeted country (2023) 

Name of VoD Provider  Targeted 
Country 

% of European Works  % of European Works 

% of EU Works 

% of EU Works 2 

% of UK Works 

2 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Amazon Prime Video 

Source: JustWatch 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

48% 

41% 

36% 

37% 

48% 

31% 

36% 

47% 

30% 

44% 

37% 

39% 

28% 

53% 

36% 

39% 

39% 

30% 

35% 

37% 

38% 

30% 

41% 

35% 

28% 

28% 

41% 

24% 

30% 

38% 

23% 

37% 

29% 

30% 

23% 

44% 

30% 

32% 

32% 

24% 

26% 

29% 

29% 

24% 

38% 

31% 

24% 

24% 

38% 

18% 

25% 

35% 

18% 

35% 

24% 

26% 

15% 

43% 

24% 

26% 

26% 

18% 

25% 

26% 

26% 

18% 

31% 

25% 

17% 

17% 

31% 

13% 

20% 

27% 

12% 

28% 

18% 

18% 

10% 

34% 

19% 

21% 

20% 

13% 

18% 

20% 

18% 

13% 

11% 

11% 

14% 

16% 

11% 

13% 

13% 

15% 

14% 

11% 

14% 

17% 

13% 

13% 

12% 

13% 

14% 

13% 

11% 

12% 

16% 

14% 

232 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 49: Share of European works, EU27 works, and UK works in the catalogues of Apple TV per targeted country (2023) 

Name of VoD Provider 

Targeted  
Country 

% of European Works  % of European Works 

% of EU Works 

% of EU Works 2 

% of UK Works 

2 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Apple TV 

Source: JustWatch 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

SE 

40% 

36% 

23% 

25% 

43% 

31% 

24% 

23% 

33% 

28% 

46% 

24% 

31% 

41% 

25% 

26% 

37% 

30% 

23% 

21% 

29% 

32% 

29% 

17% 

18% 

35% 

24% 

18% 

17% 

22% 

20% 

37% 

17% 

23% 

31% 

18% 

19% 

27% 

22% 

17% 

15% 

21% 

30% 

26% 

12% 

14% 

32% 

21% 

13% 

12% 

22% 

17% 

36% 

13% 

17% 

31% 

14% 

14% 

25% 

18% 

12% 

11% 

18% 

22% 

20% 

7% 

9% 

24% 

15% 

8% 

7% 

14% 

11% 

28% 

8% 

10% 

23% 

9% 

9% 

18% 

12% 

7% 

7% 

12% 

12% 

10% 

11% 

10% 

13% 

12% 

11% 

10% 

13% 

12% 

12% 

11% 

15% 

13% 

11% 

11% 

13% 

12% 

10% 

11% 

12% 

233 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 50: Share of European works, EU27 works, and UK works in the catalogues of Mubi per targeted country (2023) 
% of European Works  % of European Works 

Name of VoD Provider 

% of EU Works 

% of EU Works 2 

Targeted  
Country 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi Amazon Channel 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi Amazon Channel 

Mubi 

Mubi 

Mubi Amazon Channel 

Mubi 

Mubi 

Mubi 

Mubi Amazon Channel 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Source: JustWatch 

AT 

BE 

BG 

CZ 

DE 

DE 

DK 

EE 

EL 

ES 

ES 

FI 
FR 

FR 

HU 

IE 

IT 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

2 

59% 

60% 

60% 

58% 

62% 

63% 

58% 

58% 

59% 

56% 

55% 

58% 

61% 

69% 

59% 

63% 

64% 

70% 

58% 

58% 

60% 

58% 

58% 

57% 

60% 

59% 

49% 

50% 

50% 

48% 

52% 

52% 

46% 

48% 

48% 

46% 

45% 

47% 

51% 

60% 

49% 

52% 

54% 

60% 

49% 

49% 

50% 

47% 

47% 

47% 

50% 

47% 

53% 

53% 

54% 

52% 

56% 

57% 

49% 

52% 

52% 

49% 

49% 

49% 

53% 

63% 

53% 

55% 

57% 

63% 

52% 

52% 

53% 

49% 

51% 

49% 

53% 

50% 

% of UK Works 

41% 

41% 

41% 

39% 

43% 

43% 

34% 

40% 

39% 

37% 

36% 

35% 

41% 

51% 

40% 

40% 

45% 

49% 

40% 

40% 

41% 

35% 

38% 

38% 

40% 

35% 

7% 

9% 

6% 

6% 

7% 

7% 

11% 

6% 

7% 

7% 

7% 

11% 

9% 

8% 

6% 

11% 

7% 

9% 

6% 

6% 

8% 

11% 

6% 

8% 

6% 

11% 

234 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Comparing  the  share  of  European  works  per  country  catalogue  for  the  largest  four  VoD  service 
providers between 2020-2021 and 2023 

There are notable differences in the share of European works in the catalogues of the same service depending 
on the target country. 

As shown in Table 51, the Netflix catalogue has the highest share of European works in Czechia with 52% (8 
pp increase from 2020-2021), followed by Romania (48%, 13 pp increase) and France (46%, 13 pp increase). 
On the other hand, the Netflix catalogue has the lowest shares in Ireland (35%, 10 pp increase from 2021). 
Overall, the share of European works per country in the Netflix catalogue increased as an average between 
5% and 18% for all targeted countries. 

As shown in Table 52, the Amazon Prime Video catalogue has the highest percentage in Italy with 53% (6 pp 
increase from 2020-2021), followed by Austria (48%, 5 pp increase) and Germany (48%, 5 pp increase). On 
the other hand, the Amazon Prime Video catalogue has the lowest shares in Ireland (28%, 6 pp increase from 
2020-2021). Overall, the share of European works per country Amazon Prime Video catalogue increased on 
average between 2% and 24% for all targeted countries, except Belgium (no change) and Spain (30%, 12 pp 
decrease). 

As shown in Table 53, the Apple iTunes/Apple TV catalogue has the highest percentage in France with 46% 
(3 pp increase from 2021), followed by Germany (43%, 1 pp increase) and Italy (41%, 5 pp increase). On the 
other hand, the Apple iTunes/Apple TV catalogue has the lowest shares in Portugal (21%, 2 pp increase from 
2021).  Overall,  the  share  of  European  works  per  country  Apple  iTunes/Apple  TV  catalogue  increased  all 
countries analysed. 

As shown in Table 59, all of the Mubi catalogues analysed contain above 50% of European works in 2021). 
All Mubi catalogues analysed increased in relative size from 2021 to 2023 in all countries except Germany. In 
Germany, the share of European works in the Mubi Amazon Channel decreased from 70% in 2021 to 63% in 
2023 (7 percentage points decrease) and in the Mubi catalogue from 63% to 62% (1 pp decrease). 

Table 51: Share of European works in the catalogues of Netflix per targeted country 

Name of VoD Provider 

Targeted 
Country 

% of European 
works (2021) 

% of European 
works (2023) 

Difference 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

IE 

34% 

34% 

26% 

44% 

34% 

32% 

26% 

33% 

31% 

32% 

31% 

39% 

25% 

41% 

39% 

44% 

52% 

41% 

42% 

44% 

44% 

43% 

38% 

46% 

46% 

35% 

7% 

5% 

18% 

8% 

7% 

10% 

18% 

11% 

12% 

6% 

15% 

7% 

10% 

235 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

Netflix 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

32% 

26% 

26% 

34% 

32% 

37% 

31% 

35% 

32% 

43% 

44% 

44% 

44% 

44% 

42% 

45% 

48% 

42% 

11% 

18% 

18% 

10% 

12% 

5% 

14% 

13% 

10% 

Source: JustWatch 

Table 52: Share of European works in the catalogues of Amazon Prime Video per targeted country 

Name of VoD Provider 

Targeted 
Country 

% of European 
works (2021) 

% of European 
works (2023) 

Difference 

Amazon Prime Video 

AT 

Amazon Prime Video 

BE 

Amazon Prime Video 

BG 

Amazon Prime Video 

CZ 

Amazon Prime Video 

DE 

Amazon Prime Video 

DK 

Amazon Prime Video 

EE 

Amazon Prime Video 

EL 

Amazon Prime Video 

ES 

Amazon Prime Video 

FI 

Amazon Prime Video 

FR 

Amazon Prime Video 

HU 

Amazon Prime Video 

Amazon Prime Video 

IE 

IT 

Amazon Prime Video 

LT 

Amazon Prime Video 

LV 

Amazon Prime Video 

NL 

43% 

39% 

27% 

24% 

43% 

21% 

23% 

23% 

42% 

21% 

37% 

23% 

22% 

47% 

23% 

21% 

35% 

48% 

41% 

36% 

37% 

48% 

31% 

36% 

47% 

30% 

44% 

37% 

39% 

28% 

53% 

36% 

39% 

39% 

5% 

2% 

9% 

13% 

5% 

10% 

13% 

24% 

-12% 

23% 

0% 

16% 

6% 

6% 

13% 

18% 

4% 

236 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Amazon Prime Video 

NO 

Amazon Prime Video 

PL 

Amazon Prime Video 

PT 

Amazon Prime Video 

RO 

Amazon Prime Video 

SE 

Source: JustWatch 

21% 

30% 

32% 

24% 

21% 

30% 

35% 

37% 

38% 

30% 

9% 

5% 

5% 

14% 

9% 

Table 53: Share of European works in the catalogues of Apple iTunes* per targeted country 

Name of VoD Provider 

Targeted 
Country 

% of European 
works (2021) 

% of European 
works (2023) 

Difference 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

Apple iTunes 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

SE 

38% 

35% 

22% 

23% 

42% 

30% 

21% 

21% 

30% 

26% 

43% 

22% 

28% 

36% 

22% 

22% 

34% 

29% 

21% 

19% 

27% 

40% 

36% 

23% 

25% 

43% 

31% 

24% 

23% 

33% 

28% 

46% 

24% 

31% 

41% 

25% 

26% 

37% 

30% 

23% 

21% 

29% 

2% 

1% 

1% 

2% 

1% 

1% 

3% 

12% 

-2% 

20% 

-20% 

2% 

3% 

5% 

3% 

4% 

3% 

1% 

2% 

2% 

2% 

Source: JustWatch. *Apple iTunes data from 2021; Apple TV data from 2023.  

237 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Table 54: Share of European works in the catalogues of Mubi per targeted country 

Name of VoD Provider 

Targeted 
Country 

% of European 
works (2021) 

% of European 
works (2023) 

Difference 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

AT 

BE 

BG 

CZ 

DE 

Mubi Amazon Channel 

DE 

Mubi 

Mubi 

Mubi 

DK 

EE 

ES 

Mubi Amazon Channel 

ES 

Mubi 

Mubi 

FI 

FR 

Mubi Amazon Channel 

FR 

Mubi 

Mubi 

Mubi 

Mubi 

GR 

HU 

IE 

IT 

Mubi Amazon Channel 

IT 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

Mubi 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

57% 

54% 

54% 

53% 

63% 

70% 

57% 

54% 

52% 

- 

57% 

53% 

- 

54% 

54% 

57% 

52% 

- 

54% 

55% 

56% 

57% 

53% 

53% 

55% 

58% 

59% 

60% 

60% 

58% 

62% 

63% 

58% 

58% 

56% 

55% 

58% 

61% 

69% 

59% 

59% 

63% 

64% 

70% 

58% 

58% 

60% 

58% 

58% 

57% 

60% 

59% 

2% 

6% 

6% 

5% 

-1% 

-7% 

1% 

4% 

- 

- 

1% 

8% 

- 

5% 

5% 

6% 

12% 

- 

4% 

3% 

4% 

1% 

5% 

4% 

5% 

1% 

Source: JustWatch 

Table  55 compares the share of European works (both definitions), EU27 works (both definitions), and UK 
works across the top five services by number of productions per target country.  

238 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

The  analysis  shows  that  some  services  have  a  much  stronger  focus  on  European  works  than  others.  For 
example, Netflix catalogues have between 39% and 52% of European works in all countries where they are 
present,  according  to  the  first  definition  of  European  works  and  34%  and  47%  according  to  the  second 
definition.  A  similar  trend  can  be  observed  when  comparing  the  figures  based  on  the  two  EU27  works 
indicators: Netflix catalogues have between 29% and 37% of European works in all countries where they are 
present according to the first definition of EU27 works and 24% and 33% according to the second definition. 
The share of UK works in the Netflix catalogues is much smaller compared to European and EU27 works  -
Netflix  catalogues  have  between  9%  and  13%  of  UK  works  in  all  countries  for  which  the  analysis  was 
conducted.  

Table 55 also shows the differences noted at country level when the data is aggregated. In Austria, France, 
Germany, and Italy, most of the top catalogues contain more than 40% of European works according to the 
first definition. These figures differ according to the second definition. According to the second definition, none 
of the countries analysed have a majority of top catalogues that contain more than 40% of European works. 
Instead, in Austria, Belgium, France, Germany, and Italy, most of the top catalogues contain more than 30% 
of European works according to the second definition. On the other hand, most of the largest catalogues in the 
following countries contain less than 30% of European works according to the first definition: Bulgaria, Czechia, 
Estonia, Greece, Hungary, Latvia, Lithuania, Poland, and Portugal. 

When looking at the EU27 indicators, we observe that in Austria, France, Germany, and Italy, most of the top 
catalogues contain more than 30% of EU27 works according to the first definition, and 20% according to the 
second definition. On the other hand, most of the large catalogues in the following countries contain less than 
20%  of  EU27  works:  Bulgaria,  Estonia,  Finland,  Greece,  Hungary,  Ireland,  Latvia,  Lithuania,  Netherlands, 
Norway, and Sweden. 

Finally, we compared the share of UK works across the top five services per target country. Overall, the share 
of UK works across these top catalogues is much lower than that of European works and EU27 works across 
both definitions. Nevertheless, the analysis revealed that most of the large catalogues (Mubi, Netflix, Amazon 
Prime, Apple TV) in the following countries contain more than 15% of UK works: Austria, Czechia, Denmark, 
Finland, France, Hungary, Norway, Poland, Portugal, Spain, and Sweden. 

239 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 55: Top five services included in the analysis by number of productions – comparison across all indicators (2023) 

Country  

Service 

% of European Works 

% of European Works 2 

% of EU Works 

% of EU Works 2 

% of UK Works 

Amazon Video 

Apple TV 

Austria 

Google Play Movies 

maxdome Store 

Rakuten TV 

Apple TV 

Google Play Movies 

Belgium 

Bulgaria 

Netflix 

Sooner 

Rakuten TV 

Apple TV 

Netflix 

Sun Nxt 

Disney Plus 

Zee5 

Apple TV 

Netflix 

Czechia 

Google Play Movies 

Sun Nxt 

HBO Max 

Amazon Video 

Apple TV 

Germany 

Google Play Movies 

YouTube 

MagentaTV 

Apple TV 

SF Anytime 

Denmark 

Google Play Movies 

Blockbuster 

44% 

40% 

48% 

40% 

44% 

36% 

42% 

39% 

79% 

34% 

23% 

44% 

0.5% 

12% 

2% 

25% 

52% 

23% 

0.5% 

40% 

44% 

43% 

48% 

48% 

48% 

31% 

42% 

35% 

43% 

37% 

32% 

40% 

30% 

32% 

29% 

32% 

34% 

69% 

22% 

17% 

40% 

0.4% 

7% 

1% 

18% 

47% 

12% 

0.4% 

32% 

37% 

35% 

39% 

39% 

39% 

24% 

31% 

26% 

33% 

34% 

30% 

38% 

30% 

33% 

26% 

32% 

29% 

74% 

23% 

12% 

30% 

0.2% 

5% 

1% 

14% 

37% 

12% 

0.2% 

29% 

34% 

32% 

38% 

38% 

38% 

21% 

30% 

24% 

33% 

27% 

22% 

30% 

21% 

24% 

20% 

24% 

24% 

61% 

15% 

7% 

26% 

0.2% 

2% 

1% 

9% 

33% 

6% 

0.2% 

23% 

27% 

24% 

30% 

29% 

30% 

15% 

21% 

17% 

24% 

11% 

12% 

12% 

13% 

14% 

10% 

11% 

9% 

8% 

13% 

11% 

12% 

0.3% 

8% 

1% 

10% 

13% 

13% 

0.3% 

12% 

11% 

13% 

12% 

12% 

12% 

12% 

15% 

13% 

12% 

240 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Country  

Service 

Viaplay 

Apple TV 

Netflix 

Estonia 

Google Play Movies 

Spain 

Sun Nxt 

Disney Plus 

Apple TV 

Filmin 

Netflix 

Google Play Movies 

Rakuten TV 

Apple TV 

SF Anytime 

Finland 

Google Play Movies 

Telia Play 

Blockbuster 

Apple TV 

Orange VOD 

France 

Google Play Movies 

YouTube 

Amazon Video 

Apple TV 

Netflix 

Greece 

Google Play Movies 

Sun Nxt 

Disney Plus 

Apple TV 

Netflix 

YouTube 

Google Play Movies 

Hungary 

% of European Works 

% of European Works 2 

% of EU Works 

% of EU Works 2 

% of UK Works 

40% 

24% 

44% 

18% 

0.5% 

13% 

33% 

62% 

44% 

34% 

39% 

28% 

40% 

32% 

40% 

36% 

46% 

68% 

45% 

45% 

42% 

23% 

46% 

19% 

0.5% 

14% 

24% 

46% 

19% 

19% 

28% 

18% 

40% 

8% 

0.4% 

7% 

22% 

53% 

40% 

22% 

26% 

20% 

29% 

22% 

29% 

25% 

37% 

58% 

35% 

35% 

32% 

17% 

42% 

9% 

0.4% 

8% 

17% 

41% 

9% 

9% 

28% 

13% 

30% 

8% 

0.2% 

6% 

22% 

51% 

32% 

24% 

29% 

17% 

28% 

20% 

27% 

24% 

36% 

60% 

36% 

37% 

34% 

12% 

33% 

9% 

0.2% 

5% 

13% 

33% 

9% 

9% 

18% 

8% 

27% 

3% 

0.2% 

2% 

14% 

41% 

28% 

14% 

19% 

11% 

19% 

12% 

18% 

15% 

28% 

49% 

27% 

27% 

24% 

7% 

29% 

3% 

0.2% 

2% 

8% 

28% 

3% 

3% 

15% 

11% 

12% 

11% 

0.3% 

8% 

13% 

13% 

11% 

13% 

14% 

12% 

15% 

14% 

16% 

15% 

12% 

12% 

12% 

11% 

12% 

10% 

12% 

12% 

0.3% 

9% 

11% 

12% 

12% 

12% 

241 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Country  

Service 

Sun Nxt 

Apple TV 

Google Play Movies 

Ireland 

Sky Store 

Amazon Prime Video 

Rakuten TV 

Apple TV 

Amazon Video 

Italy 

Google Play Movies 

Chili 

Netflix 

Apple TV 

Netflix 

Lithuania 

Google Play Movies 

Sun Nxt 

Disney Plus 

Apple TV 

Netflix 

Latvia 

Google Play Movies 

Sun Nxt 

Disney Plus 

Microsoft Store 

Apple TV 

Netherlands 

Google Play Movies 

Amazon Video 

Netflix 

Apple TV 

SF Anytime 

Google Play Movies 

Blockbuster 

Norway 

% of European Works 

% of European Works 2 

% of EU Works 

% of EU Works 2 

% of UK Works 

0.5% 

31% 

30% 

33% 

28% 

34% 

41% 

40% 

43% 

49% 

43% 

25% 

44% 

19% 

0.5% 

13% 

26% 

44% 

18% 

0.5% 

13% 

25% 

37% 

36% 

32% 

44% 

30% 

41% 

34% 

38% 

0.4% 

0.2% 

23% 

22% 

23% 

23% 

22% 

31% 

29% 

32% 

41% 

38% 

18% 

40% 

8% 

0.4% 

7% 

19% 

40% 

8% 

0.4% 

7% 

16% 

27% 

26% 

20% 

38% 

22% 

30% 

24% 

26% 

17% 

17% 

16% 

15% 

18% 

31% 

32% 

34% 

42% 

30% 

14% 

30% 

9% 

0.2% 

6% 

14% 

30% 

8% 

0.2% 

6% 

16% 

25% 

25% 

21% 

30% 

18% 

27% 

20% 

25% 

0.2% 

10% 

10% 

7% 

10% 

8% 

23% 

23% 

24% 

34% 

26% 

9% 

27% 

3% 

0.2% 

2% 

9% 

27% 

3% 

0.2% 

2% 

9% 

18% 

17% 

13% 

26% 

12% 

18% 

12% 

15% 

0.3% 

15% 

15% 

21% 

13% 

21% 

13% 

12% 

13% 

10% 

12% 

11% 

12% 

12% 

0.3% 

8% 

11% 

12% 

11% 

0.3% 

8% 

11% 

13% 

13% 

13% 

12% 

12% 

15% 

14% 

15% 

242 

 
 
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Country  

Poland 

Portugal 

Romania 

Service 

Viaplay 

Apple TV 

Netflix 

Horizon 

YouTube 

Google Play Movies 

Apple TV 

Netflix 

YouTube 

Google Play Movies 

Meo 

Netflix 

Sun Nxt 

Horizon 

HBO Max 

Disney Plus 

Apple TV 

SF Anytime 

Sweden 

Google Play Movies 

Blockbuster 

Viaplay 

Source: JustWatch

% of European Works 

% of European Works 2 

% of EU Works 

% of EU Works 2 

% of UK Works 

40% 

23% 

42% 

46% 

19% 

19% 

21% 

45% 

19% 

19% 

48% 

48% 

0.5% 

38% 

37% 

14% 

29% 

44% 

33% 

38% 

41% 

29% 

17% 

37% 

37% 

8% 

8% 

15% 

41% 

9% 

9% 

34% 

43% 

0.4% 

27% 

29% 

7% 

21% 

34% 

24% 

26% 

29% 

27% 

12% 

31% 

34% 

9% 

9% 

11% 

32% 

9% 

9% 

38% 

33% 

0.2% 

28% 

26% 

6% 

18% 

33% 

22% 

26% 

28% 

17% 

7% 

27% 

26% 

2% 

2% 

7% 

28% 

3% 

3% 

25% 

29% 

0.2% 

18% 

20% 

2% 

12% 

23% 

14% 

16% 

19% 

15% 

10% 

9% 

14% 

12% 

12% 

11% 

12% 

11% 

11% 

16% 

13% 

0.3% 

12% 

12% 

9% 

12% 

14% 

14% 

15% 

15% 

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Comparing the top five to seven services included in the analysis by number of productions as share 
of European works for 2021 and 2023 

As shown in Table 56, it is also clear that some services have a much stronger focus on European works than 
others. For example, DocAlliance catalogues have around 60% of European works in all countries where they 
are present and Mubi catalogues have also around 55% in both 2021 and 2023. 

Table 56 compares the share of European works in the catalogues of those services with the highest number 
of titles in the catalogue. The differences noted at country level when the data is aggregated are also evident 
in this table. In France, Italy, Denmark, Austria and Germany, most of the large catalogues, except Microsoft 
Store, contain more than 40% of European works. In the Netherlands, Norway, Spain, Sweden and Belgium, 
the largest catalogues contain more than 30% of European works.  

Table  56:  Top  five  to  seven  services  included  in  the  analysis  by  number  of  productions  –  share  of 
European works 

Country  

Service 

Chili 

% of European 
works (2021) 

% of European works 
(2023) 
- 

24% 

Amazon Prime Video 

Google Play Movies 

Austria 

Rakuten TV 

- 

Amazon Video 

Apple iTunes 

maxdome Store 

33% 

- 

37% 

32% 

31% 

39% 

Amazon Prime Video 

39% 

- 

Sooner 

Belgium 

Google Play Movies 

Netflix 

Apple iTunes 

Rakuten TV 

DocAlliance Films 

HBO Go 

Disney Plus 

Zee5 

Apple iTunes 

Sun Nxt 

Netflix 

O2 TV 

DocAlliance Films 

Google Play Movies 

HBO Max 

Apple iTunes 

Sun Nxt 

Netflix 

Amazon Prime Video 

- 

- 

- 

- 

Bulgaria 

Czechia 

Denmark 

Netflix 

Google Play Movies 

72% 

39% 

34% 

35% 

33% 

60% 

36% 

2% 

22% 

26% 

34% 

58% 

21% 

23% 

44% 

21% 

32% 

32% 

- 

- 

- 

- 

Difference 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

11% 

12% 

9% 

1% 

7% 

3% 

5% 

1% 

1% 

23% 

-20% 

26% 

1% 

14% 

1% 

17% 

7% 

48% 

44% 

44% 

40% 

40% 

79% 

42% 

39% 

36% 

34% 

22% 

25% 

2% 

0.4% 

52% 

35% 

72% 

22% 

40% 

40% 

0.5% 

51% 

43% 

11% 

244 

 
 
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Country  

Service 

% of European 
works (2021) 

% of European works 
(2023) 

Difference 

Apple iTunes 

Blockbuster 

SF Anytime 

Viaplay 

DocAlliance Films 

Mubi 

GuideDoc 

Netflix 

Apple iTunes 

Google Play Movies 

Disney Plus 

Sun Nxt 

Amazon Prime Video 

Netflix 

SF Anytime 

Telia Play 

Blockbuster 

Google Play Movies 

- 

- 

- 

- 

- 

- 

Apple iTunes 

Canal VoD 

Universcine 

Microsoft Store 

Orange VoD 

Apple iTunes 

YouTube 

Google Play Movies 

Amazon Video 

- 

maxdome Store 

EntertainTV 

Google Play Movies 

YouTube 

MagentaTV 

Amazon Video 

Apple iTunes 

DocAlliance Films 

Mubi 

Netflix 

Apple iTunes 

Google Play Movies 

Disney Plus 

Sun Nxt 

Horizon 

Netflix 

- 

- 

- 

30% 

40% 

59% 

54% 

49% 

26% 

21% 

17% 

- 

- 

- 

21% 

32% 

- 

- 

35% 

29% 

26% 

56% 

74% 

33% 

66% 

43% 

43% 

43% 

46% 

45% 

45% 

45% 

40% 

42% 

60% 

54% 

33% 

21% 

17% 

- 

- 

- 

- 

- 

- 

- 

36% 

- 

39% 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

43% 

48% 

42% 

40% 

44% 

24% 

18% 

13% 

0.5% 

40% 

40% 

36% 

32% 

28% 

68% 

46% 

45% 

45% 

42% 

48% 

48% 

48% 

44% 

43% 

46% 

23% 

19% 

14% 

0.5% 

46% 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

13% 

8% 

18% 

3% 

1% 

1% 

3% 

2% 

2% 

3% 

2% 

2% 

3% 

3% 

4% 

1% 

13% 

2% 

2% 

7% 

245 

 
 
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works in audiovisual media services 

Country  

Service 

% of European 
works (2021) 

% of European works 
(2023) 

Difference 

Apple iTunes 

YouTube 

Google Play Movies 

Sun Nxt 

Netflix 

Rakuten TV 

Sky Store 

Apple iTunes 

- 

Google Play Movies 

Amazon Prime Video 

Amazon Prime Video 

Rakuten TV 

Chili 

Netflix 

Google Play Movies 

Apple iTunes 

Amazon Video 

- 

DocAlliance Films 

Mubi 

Netflix 

Apple iTunes 

Google Play Movies 

Disney Plus 

Sun Nxt 

DocAlliance Films 

Telia Play 

Netflix 

Apple iTunes 

Google Play Movies 

Disney Plus 

Sun Nxt 

KPN 

Rakuten TV 

Netflix 

Apple iTunes 

Microsoft Store 

Google Play Movies 

Amazon Video 

Strim 

Amazon Prime Video 

SF Anytime 

Viaplay 

Blockbuster 

Google Play Movies 

- 

- 

- 

- 

- 

- 

- 

- 

Ireland 

Italy 

Latvia 

Lithuania 

Netherlands 

Norway 

22% 

18% 

18% 

25% 

- 

33% 

32% 

28% 

27% 

22% 

47% 

43% 

46% 

32% 

40% 

36% 

60% 

55% 

26% 

22% 

17% 

59% 

41% 

26% 

22% 

17% 

42% 

29% 

34% 

34% 

34% 

- 

- 

- 

- 

- 

- 

- 

- 

39% 

21% 

- 

- 

36% 

31% 

24% 

19% 

19% 

0.5% 

34% 

33% 

31% 

30% 

28% 

49% 

43% 

43% 

41% 

40% 

44% 

26% 

18% 

13% 

0.5% 

44% 

25% 

19% 

13% 

0.5% 

44% 

37% 

37% 

36% 

32% 

41% 

40% 

38% 

34% 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

2% 

1% 

1% 

1% 

1% 

3% 

3% 

6% 

3% 

11% 

3% 

5% 

18% 

4% 

1% 

18% 

3% 

2% 

10% 

3% 

2% 

2% 

3% 

246 

 
 
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Country  

Service 

% of European 
works (2021) 

% of European works 
(2023) 

Difference 

Poland 

Portugal 

Romania 

Spain 

Sweden 

Apple iTunes 

Chili 

Horizon 

Netflix 

Apple iTunes 

YouTube 

Google Play Movies 

Meo 

Netflix 

Apple iTunes 

YouTube 

Google Play Movies 

DocAlliance Films 

Mubi 

HBO Go 

Netflix 

Horizon 

HBO Max 

Disney Plus 

Sun Nxt 

Amazon Prime Video 

Filmin 

Netflix 

Rakuten TV 

Google Play Movies 

Apple iTunes 

Amazon Prime Video 

Netflix 

SF Anytime 

Viaplay 

Blockbuster 

Google Play Movies 

Apple iTunes 

- 

- 

- 

- 

- 

- 

29% 

29% 

- 

37% 

21% 

18% 

18% 

47% 

31% 

19% 

18% 

18% 

60% 

55% 

34% 

35% 

34% 

- 

- 

- 

42% 

- 

60% 

31% 

37% 

33% 

30% 

21% 

32% 

35% 

31% 

27% 

- 

- 

30% 

46% 

42% 

23% 

19% 

19% 

48% 

45% 

21% 

19% 

19% 

48% 

38% 

37% 

14% 

0.5% 

62% 

44% 

39% 

34% 

33% 

44% 

41% 

38% 

33% 

29% 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1% 

5% 

2% 

1% 

1% 

1% 

14% 

2% 

1% 

1% 

13% 

4% 

2% 

13% 

2% 

1% 

3% 

3% 

2% 

2% 

Source: JustWatch 

5.2.4     Countries of production and co-production in European works  

We also analysed the JustWatch data by looking at the main countries of (co-)production in all the catalogues 
of a given targeted country. In other words, we took all the catalogues of a country and identified the top (co-) 
production countries across all the catalogues. The table below shows the top 10 (co-)production countries 
per target country as well as the number of productions in the target country with participation of the top 10 
countries across all the catalogues and the share of total productions. The countries for which we have done 
this analysis is a select group of some EU and one non-EU countries. 

In  2020-2021,  the  US  was  systematically  the  leading  country  of  (co-)production  in  21  out  of  22  countries 
analysed.  Table  57  shows  that  this  trend  remained  the  same  in  2023.  Depending  on  the  target  country, 
between 35% and 53% of productions in all catalogues had a US company participating in the production in 
2023, compared to 42% and 57% in 2021. Overall, the share of US (co-)productions is always substantially 

247 

 
 
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higher  than  that  of  the  second  country  of  (co-)production.  When  summing  up  all  the  productions  in  all  the 
catalogues analysed, the US participated in 49% of them as a production or (co-)production country in 2023, 
a four-percentage point increase since 2021. While this overall figure increased since 2021, the share of US 
(co-) productions per target country: 

‒  decreased in ten countries: Belgium (-12 pp), Portugal (-6 pp), Romania (-4 pp), Hungary (-4 pp), 

Czechia (-4 pp), Greece (-2 pp), Netherlands (-2 pp), Italy (-1 pp), Denmark (-1 pp), and France (-1 pp) 

‒ 

increased in nine countries: Ireland (4 pp), Germany (4 pp), Estonia (2 pp), Latvia (1 pp), Poland (1 
pp), Finland (1 pp), Spain (1 pp), Lithuania (1 pp), and Sweden (1 pp)  

‒  did not change in three countries: Austria, Bulgaria, Norway 

Other European countries with an important share of (co)productions are: 

‒  The UK is in the top (co-)production countries across all the 22 target country catalogues. The UK (co-
)productions account for approximately 10% of all the productions analysed, an increase of 1 pp since 
2021;  

‒  France is also systematically in the top 10 (co-)production countries across all the 22 target country 

catalogues. French (co-)productions account for approximately 8% of all the productions analysed, an 
increase of 1 pp since 2021;  

‒  Germany is also one of the top 10 (co-)production countries across all the catalogues in the 22 target 
countries, though its ranking differs greatly across these countries. German (co-)productions account 
for 6% of the productions analysed.  

‒ 

Italy is also one of the top 10 (co-)production countries across all the catalogues in the 22 target 
countries, though its ranking differs across these countries. Italian (co-)productions account for 3% of 
the productions analysed. 

The other two countries that frequently feature in the top 10 (co-)production countries are Spain (in the top 10 
in  18  countries)  and  Sweden  (in  the  top  10  in  12  countries).  As  we  analysed  the  data  only  for  the  top  10 
countries,  and  these  countries  are  not  always  in  the  top  10,  their  share  of  all  (co-)productions  cannot  be 
analysed precisely but is likely between 1% and 2%.  

Other prominent non-European countries of (co)production are: 

‒ 

India – in the top 10 in all the 22 target country catalogues, participating in 11% of all the productions 
analysed, an increase of 7 pp since 2021;  

‒  Canada – in the top 10 in all the 22 target country catalogues, participating in 4% of all the productions 

analysed; 

‒  Japan - in the top 10 in all the 22 target country catalogues, participating in 3% of all the productions 

analysed, an increase of 1 pp since 2021; 

Table 57: Top production and  co-production countries per target country  according to number of 
productions and their share in total productions (2021 versus 2023) 

Target 
Countr
y  

Country of 
(co)production 
(2021) 
US 

No of 
productions 
(2021) 
20 340  

% of all 
productions 
(2021) 
44% 

Country of 
(co)production 
(2023) 
US 

No of 
productions 
(2023) 
25 598  

% of all 
productions 
(2023) 
44% 

AT 

Germany 

UK 

France 

Canada 

Japan 

Italy 

Austria 

India 

Spain 

  7 139  

  4 014  

  3 213  

  1 950  

  1 551  

  1 341  

  1 297  

  1 092  

      900  

15% 

Germany 

9% 

7% 

4% 

3% 

3% 

3% 

2% 

2% 

UK 

France 

India 

Canada 

Japan 

Italy 

Spain 

Austria 

  8 305  

  5 447  

  4 385  

  4 364  

  2 634  

  2 144  

  2 098  

  1 362  

  1 232  

14% 

9% 

8% 

8% 

5% 

4% 

4% 

2% 

2% 

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Target 
Countr
y  

Country of 
(co)production 
(2021) 
France 

No of 
productions 
(2021) 
  3 422  

% of all 
productions 
(2021) 
12% 

Country of 
(co)production 
(2023) 
France 

No of 
productions 
(2023) 
  5 489  

% of all 
productions 
(2023) 
13% 

UK 

Germany 

Canada 

BE 

India 

Belgium 

Italy 

Netherlands 

Japan 

US 

India 

UK 

Franca 

Japan 

Canada 

Germany 

Spain 

South Korea 

China 

US 

UK 

India 

France 

Canada 

Germany 

Czechia 

China 

Australia 

Japan 

US 

Germany 

UK 

Franca 

Canada 

Japan 

Italy 

Austria 

Spain 

India 

US 

UK 

BE 

CZ 

DE 

DK 

  2 431  

  1 740  

  1 311  

  1 098  

      811  

      720  

      702  

      557  

  9 036  

  1 750  

  1 441  

      831  

      774  

      573  

      547  

      307  

      305  

      270  

  9 712  

  1 568  

      992  

      908  

      639  

      615  

      481  

      264  

      257  

      252  

20 709  

  7 837  

  4 239  

3 354  

2 006  

1 823  

1 389  

1 119  

896  

787  

15 756  

3 032  

9% 

6% 

5% 

4% 

3% 

3% 

3% 

2% 

50% 

10% 

8% 

5% 

4% 

3% 

3% 

2% 

2% 

1% 

57% 

9% 

6% 

5% 

4% 

4% 

3% 

2% 

1% 

1% 

42% 

16% 

9% 

7% 

4% 

4% 

3% 

2% 

2% 

2% 

50% 

10% 

India 

UK 

Canada 

Germany 

Belgium 

Japan 

Italy 

Spain 

US 

India 

UK 

France 

Canada 

Germany 

Japan 

Italy 

Spain 

Sweden 

US 

India 

UK 

France 

Canada 

Germany 

Japan 

Italy 

Spain 

Czechia 

US 

Germany 

UK 

France 

India 

Canada 

Japan 

Italy 

Spain 
Republic of Korea 
(South Korea) 
US 

UK 

  4 387  

  3 850  

  2 191  

  2 026  

  1 709  

  1 427  

  1 424  

  1 034  

17 379  

  6 239  

  3 314  

  2 045  

  1 338  

  1 259  

  1 203  

      899  

      744  

      550  

17 919  

  4 258  

  3 369  

  2 066  

  1 440  

  1 317  

  1 144  

      904  

      709  

      682  

29 415  

10 022  

5 972  

4 903  

4 254  

2 913  

2 382  

2 199  

1 431  

1 155  

23 575  

5 015  

10% 

9% 

5% 

5% 

4% 

3% 

3% 

2% 

50% 

18% 

9% 

6% 

4% 

4% 

3% 

3% 

2% 

2% 

53% 

13% 

10% 

6% 

4% 

4% 

3% 

3% 

2% 

2% 

46% 

16% 

9% 

8% 

7% 

5% 

4% 

3% 

2% 

2% 

49% 

11% 

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Target 
Countr
y  

Country of 
(co)production 
(2021) 
Franca 

No of 
productions 
(2021) 
1 891  

% of all 
productions 
(2021) 
6% 

Country of 
(co)production 
(2023) 
India 

No of 
productions 
(2023) 
4 964  

% of all 
productions 
(2023) 
10% 

India 

Denmark 

Canada 

Japan 

Germany 

Sweden 

Australia 

US 

UK 

India 

Franca 

Canada 

Germany 

Japan 

Spain 

China 

South Korea 

US 

Spain 

UK 

France 

Germany 

Italy 

Canada 

Japan 

India 

Mexico 

US 

UK 

India 

France 

Canada 

Japan 

Germany 

Finland 

Sweden 

Australia 

US 

France 

UK 

Germany 

1 888  

1 665  

1 426  

1 300  

1 253  

    925  

    585  

9 711  

1 634  

1 375  

937  

681  

628  

348  

347  

303  

295  

13 924  

4 035  

2 998  

2 948  

1 540  

1 303  

1 219  

1 146  

883  

801  

15 727  

2 948  

1 867  

1 631  

1 385  

1 240  

1 119  

833  

781  

565  

14 988  

8 158  

3 257  

1 977  

6% 

5% 

5% 

4% 

4% 

3% 

2% 

51% 

9% 

7% 

5% 

4% 

3% 

2% 

2% 

2% 

2% 

45% 

13% 

10% 

9% 

5% 

4% 

4% 

4% 

3% 

3% 

51% 

10% 

6% 

5% 

5% 

4% 

4% 

3% 

3% 

2% 

42% 

23% 

9% 

6% 

EE 

ES 

FI 

FR 

France 

Denmark 

Canada 

Germany 

Japan 

Sweden 

Italy 

US 

India 

UK 

France 

Canada 

Germany 

Japan 

Italy 

Spain 

Sweden 

US 

Spain 

UK 

France 

India 

Germany 

Canada 

Italy 

Japan 

Mexico 

US 

UK 

India 

France 

Canada 

Germany 

Japan 

Finland 

Sweden 

Italy 

US 

France 

UK 

India 

3 096  

2 742  

2 127  

1 978  

1 687  

1 374  

1 165  

17 694  

4 378  

3 331  

2 075  

1 393  

1 236  

1 234  

939  

751  

580  

23 232  

5 433  

4 837  

4 218  

3 985  

2 255  

2 099  

2 013  

1 609  

1 161  

23 983  

4 986  

4 949  

2 921  

2 106  

1 856  

1 666  

1 432  

1 229  

1 157  

24 225  

12 225  

4 997  

4 126  

6% 

6% 

4% 

4% 

4% 

3% 

2% 

53% 

13% 

10% 

6% 

4% 

4% 

4% 

3% 

2% 

2% 

46% 

11% 

10% 

8% 

8% 

4% 

4% 

4% 

3% 

2% 

52% 

11% 

11% 

6% 

5% 

4% 

4% 

3% 

3% 

2% 

41% 

21% 

9% 

7% 

250 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Target 
Countr
y  

Country of 
(co)production 
(2021) 
Canada 

No of 
productions 
(2021) 
1 703  

% of all 
productions 
(2021) 
5% 

Country of 
(co)production 
(2023) 
Germany 

No of 
productions 
(2023) 
2 937  

% of all 
productions 
(2023) 
5% 

Japan 

Italy 

India 

Spain 

Belgium 

US 

UK 

India 

Japan 

France 

Canada 

Germany 

Spain 

China 

Italy 

US 

UK 

India 

France 

Germany 

Canada 

Italy 

Australia 

Spain 

Japan 

US 

UK 

India 

France 

Canada 

Germany 

Japan 

Italy 

Australia 

Spain 

US 

Italy 

France 

GR 

HU 

IE 

IT 

UK 

Germany 

Canada 

Japan 

1 493  

1 438  

1 077  

830  

794  

9 120  

1 389  

982  

761  

750  

558  

515  

279  

268  

227  

9 549  

1 598  

910  

892  

630  

617 

264  

259  

254  

246  

22 325  

6 311  

3 907  

2 367  

2 327  

1 549  

1 081  

1 002  

946  

743  

13 055  

4 414  

2 564  

2 519  

1 380  

1 280  

1 208  

4% 

4% 

3% 

2% 

2% 

55% 

8% 

6% 

5% 

5% 

3% 

3% 

2% 

2% 

1% 

57% 

10% 

5% 

5% 

4% 

4% 

2% 

2% 

2% 

1% 

47% 

13% 

8% 

5% 

5% 

3% 

2% 

2% 

2% 

2% 

47% 

16% 

9% 

9% 

5% 

5% 

4% 

Canada 

Italy 

Japan 

Spain 

Belgium 

US 

India 

UK 

France 

Canada 

Japan 

Germany 

Italy 

Spain 

Sweden 

US 

India 

UK 

France 

Canada 

Germany 

Japan 

Italy 

Spain 

Sweden 

US 

UK 

India 

France 

Canada 

Japan 

Germany 

Italy 

Australia 

Spain 

US 

Italy 

UK 

India 

France 

Canada 

Germany 

2 744  

2 353  

2 001  

1 468  

1 311  

16 286  

4 311  

2 963  

1 789  

1 191  

1 188  

1 102  

858  

654  

525  

17 167  

4 430  

3 200  

1 971  

1 312  

1 182  

1 131  

823  

728  

536  

31 017  

8 325  

6 177  

3 225  

3 157  

2 435  

2 240  

1 367  

1 208  

1 117  

22 016  

6 053  

4 348  

4 014  

3 849  

2 098  

2 097  

5% 

4% 

3% 

3% 

2% 

53% 

14% 

10% 

6% 

4% 

4% 

4% 

3% 

2% 

2% 

53% 

14% 

10% 

6% 

4% 

4% 

3% 

3% 

2% 

2% 

51% 

14% 

10% 

5% 

5% 

4% 

4% 

2% 

2% 

2% 

46% 

13% 

9% 

8% 

8% 

4% 

4% 

251 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Target 
Countr
y  

Country of 
(co)production 
(2021) 
India 

No of 
productions 
(2021) 
931  

% of all 
productions 
(2021) 
3% 

Country of 
(co)production 
(2023) 
Japan 

No of 
productions 
(2023) 
1 587  

% of all 
productions 
(2023) 
3% 

Spain 

Australia 

US 

UK 

India 

France 

Canada 

Germany 

Japan 

Spain 

South Korea 

Australia 

US 

UK 

India 

France 

Canada 

Germany 

Spain 

Japan 

South Korea 

Russia 

US 

UK 

France 

Netherlands 

Japan 

Germany 

Canada 

Belgium 

India 

Spain 

US 

UK 

France 

India 

Canada 

Germany 

Netherlands 

Japan 

Belgium 

Italy 

750  

390  

9 283  

1 579  

1 353  

956  

725  

636  

342  

335  

297  

277  

9 263  

1 592  

1 326  

941  

717  

638  

341  

338  

296  

292  

11 882  

2 168  

1 520  

1 122  

1 025  

956  

938  

594  

543  

431  

23 741  

4 591  

3 829  

3 761  

2 191  

1 946  

1 911  

1 803  

1 221  

1 110  

LT 

LV 

NL 

NO 

3% 

1% 

51% 

9% 

7% 

5% 

4% 

3% 

2% 

2% 

2% 

2% 

50% 

9% 

7% 

5% 

4% 

3% 

2% 

2% 

2% 

2% 

53% 

10% 

7% 

5% 

5% 

4% 

4% 

3% 

2% 

2% 

51% 

10% 

8% 

8% 

5% 

4% 

4% 

4% 

3% 

2% 

Spain 

Sweden 

US 

India 

UK 

France 

Canada 

Germany 

Japan 

Italy 

Spain 

Sweden 

US 

India 

UK 

France 

Canada 

Germany 

Japan 

Italy 

Spain 

Sweden 

US 

UK 

France 

India 

Canada 

Germany 

Netherlands 

Japan 

Belgium 

Italy 

US 

UK 

India 

France 

Canada 

Germany 

Japan 

Norway 

Sweden 

Italy 

1 310  

666  

17 209  

4 364  

3 322  

2 181  

1 437  

1 289  

1 235  

960  

752  

618  

16 476  

4 317  

3 188  

2 068  

1 329  

1 227  

1 222  

924  

750  

598  

23 741  

4 591  

3 829  

3 761  

2 191  

1 946  

1 911  

1 803  

1 221  

1 110  

23 583  

5 087  

4 873  

2 935  

2 149  

1 879  

1 670  

1 502  

1 368  

1 149  

3% 

1% 

52% 

13% 

10% 

7% 

4% 

4% 

4% 

3% 

2% 

2% 

51% 

13% 

10% 

6% 

4% 

4% 

4% 

3% 

2% 

2% 

51% 

10% 

8% 

8% 

5% 

4% 

4% 

4% 

3% 

2% 

51% 

11% 

11% 

6% 

5% 

4% 

4% 

3% 

3% 

2% 

252 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Target 
Countr
y  

Country of 
(co)production 
(2021) 
US 

No of 
productions 
(2021) 
11 499  

% of all 
productions 
(2021) 
51% 

Country of 
(co)production 
(2023) 
US 

No of 
productions 
(2023) 
19 754  

% of all 
productions 
(2023) 
52% 

PL 

PT 

RO 

SE 

UK 

France 

India 

Poland 

Germany 

Canada 

Italy 

Spain 

Japan 

US 

UK 

France 

India 

Japan 

Canada 

Germany 

Spain 

Mexico 

Italy 

US 

UK 

France 

Japan 

India 

Germany 

Canada 

Spain 

Romania 

Italy 

US 

UK 

France 

India 

Sweden 

Canada 

Japan 

Germany 

Australia 

Denmark 

2 028  

1 614  

1 035  

1 022  

994  

883  

500  

492  

385  

9% 

7% 

5% 

5% 

4% 

4% 

2% 

2% 

2% 

11 507  

55% 

1 959  

1 475  

959  

864  

802  

772  

501  

400  

395  

9% 

7% 

5% 

4% 

4% 

4% 

2% 

2% 

2% 

4 436  

47% 

852  

814  

732  

478  

428  

366  

275  

202  

192  

16 655  

3 286  

1 966  

1 919  

1 832  

1 471  

1 302  

1 264  

616  

611  

9% 

9% 

8% 

5% 

5% 

4% 

3% 

2% 

2% 

50% 

10% 

6% 

6% 

5% 

4% 

4% 

4% 

2% 

2% 

Source: JustWatch 

5.2.5     Domestic and non-domestic European works 

India 

UK 

France 

Canada 

Germany 

Japan 

Poland 

Italy 

Spain 

US 

India 

UK 

France 

Germany 

Canada 

Japan 

Italy 

Spain 

Mexico 

US 

India 

UK 

France 

Japan 

Germany 

Canada 

Italy 

Spain 

Sweden 

US 

UK 

India 

France 

Sweden 

Canada 

Germany 

Japan 

Italy 

Spain 

4 311  

3 619  

2 386  

1 693  

1 655  

1 275  

1 187  

1 036  

851  

18 578  

4 352  

3 764  

2 908  

1 529  

1 503  

1 288  

1 090  

1 024  

691  

9 353  

3 804  

2 141  

1 844  

1 093  

1 011  

835  

768  

648  

458  

24 892  

5 213  

4 984  

3 263  

2 798  

2 231  

1 998  

1 710  

1 208  

988  

11% 

10% 

6% 

4% 

4% 

3% 

3% 

3% 

2% 

49% 

12% 

10% 

8% 

4% 

4% 

3% 

3% 

3% 

2% 

43% 

17% 

10% 

8% 

5% 

5% 

4% 

3% 

3% 

2% 

51% 

11% 

10% 

7% 

6% 

5% 

4% 

3% 

2% 

2% 

253 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

In addition, we assessed the share of domestic European works among the targeted countries and channels. 
We operationalised the indicator on domestic European works by considering that domestic European works 
are  those  works  which  had  at  least  one  production  company  originating  in  the  country  analysed  (targeted 
country) 

We looked at the share of European domestic works in 2023 using this definition in Table 58, and the change 
in relative size between the two monitoring periods for the first definition (Table 59). 

As shown in Table 58, the share of domestic European works in all European works varies greatly across the 
selected  EU  Member  States  and  Norway.  Overall,  domestic  works  represent  between  0.1%  and  56%  of 
European works in the 26 countries analysed. On the one hand, France, Germany, Italy and Spain have the 
largest share of domestic: 

‒  France: domestic works represent 56% of European works in France; 

‒  Germany: domestic works represent 40% of European works in Germany;  

‒ 

Italy: domestic works represent 35% of European works in Italy; 

‒  Spain: domestic works represent 28% of European works in Spain. 

On the other hand, domestic works represent less than 1% of European works in Bulgaria, Estonia, Greece, 
Malta, Latvia and Slovenia.  

254 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 58: Share of domestic European works (first definition) per target country 

Country  Total no of European works  No of domestic 

European works 
(movies) 

No of domestic European 
works (TV series) 

Total no of Domestic works  Share of European domestic works 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

68 430 

28 711 

11 889 

13 978 

99 242 

37 821 

12 768 

39 042 

39 386 

81 726 

10 983 

12 732 

36 765 

42 225 

13 193 

12 370 

33 614 

38 726 

19 195 

16 453 

9 070 

40 904 

Total 

719 223 

Source: JustWatch 

2 887 

3 341 

97 

1 325 

36 198 

6 133 

56 

9 731 

3 376 

43 303 

48 

256 

1 301 

13 793 

182 

64 

4 301 

3 319 

1 427 

643 

287 

6 795 

138 863 

170 

196 

8 

28 

3 950 

777 

11 

1 195 

307 

2 602 

1 

6 

50 

855 

25 

2 

785 

975 

342 

111 

8 

628 

13 032 

3 057 

3 537 

105 

1353 

40 148 

6 910 

67 

10 926 

3 683 

45 905 

49 

262 

1 351 

14 648 

207 

66 

5 086 

4 294 

1 769 

754 

295 

7 423 

151 895 

4% 

12% 

1% 

10% 

40% 

18% 

1% 

28% 

9% 

56% 

0% 

2% 

4% 

35% 

2% 

1% 

15% 

11% 

9% 

5% 

3% 

18% 

255 

 
 
  
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Comparing the share of domestic European works per target country between 2021 and 2023 

As shown in Table 59, the share of domestic European works in all European works varies greatly. While these 
represent less than 1% of European works in Greece (1 pp decrease since 2021) and Estonia (6 pp decrease), 
they are 56% in France (3 pp decrease). While most countries experienced a decrease in the share of domestic 
European works, only seven countries saw an increase of 1-4 percentage points (Norway, Italy, Spain, and 
Belgium) or no change (Lithuania, Portugal, and Bulgaria). 

For each country, the number of  European  movies  is significantly  higher than the number  of  European TV 
series. In fact, European movies count for 89% of European productions. This trend is also seen in domestic 
works, as European domestic movies represent 91% of total European domestic productions (2 pp decrease 
from 2021).  

‒  France is the country with the biggest share of domestic works, with 56%. It is followed by Germany 

(40%) and Italy (35%). 

‒  The countries with the lowest percentage of domestic European works include Greece (0.5%), Estonia 

(0.5%), Latvia (1%) and Bulgaria (1%). 

‒  12 of the 22 countries have less than 10% of domestic European works (Austria, Bulgaria, Czechia, 

Estonia, Finland, Greece, Hungary, Ireland, Lithuania, Latvia, Portugal, and Romania).  

‒  The highest shares can be observed in countries where the local industry is very strong.

256 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Country  Total no of 
European 
works (2021) 

Table 59: Share of domestic European works per target country 
No of 
Total no of 
domestic 
European 
European 
works (2023) 
works 
(movies) 
(2023) 

No of 
domestic 
European 
works 
(movies) 
(2021) 

No of 
domestic 
European 
works (TV 
series) (2021) 

No of 
domestic 
European 
works (TV 
series) (2023) 

% of European 
domestic 
works (2021) 

% of European 
domestic 
works (2023) 

Difference 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

Total 

61 874 

18 020 

6 809 

8 051 

82 976 

20 294 

9 138 

21 599 

19 764 

56 777 

6 462 

10 801 

26 849 

27 628 

7 798 

5 511 

16 251 

26 246 

13 744 

8 054 

5 616 

22 334 

482 596 

68 430 

28 711 

11 889 

13 978 

99 242 

37 821 

12 768 

39 042 

39 386 

81 726 

10 983 

12 732 

36 765 

42 225 

13 193 

12 370 

33 614 

38 726 

19 195 

16 453 

9 070 

40 904 

719 223 

3 259 

1 403 

61 

940 

32 400 

3 669 

516 

5 162 

1 988 

32 150 

44 

305 

2 076 

8 753 

124 

167 

2 127 

2 241 

1 596 

383 

278 

2 887 

3 341 

97 

1325 

36 198 

6 133 

56 

9 731 

3 376 

43 303 

48 

256 

1 301 

13 793 

182 

64 

4 301 

3 319 

1 427 

643 

287 

183 

106 

7 

19 

3 262 

278 

113 

466 

297 

1 184 

0 

26 

50 

379 

10 

8 

541 

337 

160 

18 

6 

4 075 

103 717 

6 795 

138 863 

411 

7 861 

170 

196 

8 

28 

3 950 

777 

11 

1195 

307 

2 602 

1 

6 

50 

855 

25 

2 

785 

975 

342 

111 

8 

628 

13 032 

6% 

8% 

1% 

12% 

43% 

19% 

7% 

26% 

12% 

59% 

1% 

3% 

8% 

33% 

2% 

3% 

16% 

10% 

13% 

5% 

5% 

20% 

23% 

4% 

12% 

1% 

10% 

40% 

18% 

0.5% 

28% 

9% 

56% 

0.4% 

2% 

4% 

35% 

2% 

1% 

15% 

11% 

9% 

5% 

3% 

18% 

21% 

-2% 

4% 

0% 

-2% 

-3% 

-1% 

-6% 

2% 

-3% 

-3% 

-1% 

-1% 

-4% 

2% 

0% 

-2% 

-1% 

1% 

-4% 

0% 

-2% 

-2% 

-2% 

257 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

The next tables show the share of European Domestic Works for the VoD Providers with the biggest share of 
European  works  per  target  country.  We  took  the  top  5  VoD  providers  for  each  country  from  Table  55  and 
analysed how many of the European works provided were domestic in 2023. 

The tablesTable 60 show important differences between services in the same country, for example: 

‒ 

‒ 

‒ 

In Austria, while VOD Club has 83% domestic works according to the first definition of domestic works, 
the same service has 49% domestic works according to the second definition. On the other hand, Google 
Play Movies only has 3% domestic works according to the first definition and 1% according to the second. 

In Bulgaria, while Nova Play has 64% of domestic works according to both definitions, Apple TV only has 
8% according to the first definition and 0.2% according to the second. 

In the Netherlands, Videoland has 54% of European domestic works according to the first definition and 
46% according to the second. On the other hand, Apple TV only 13% domestic works according to the 
first definition and 9% according to the second. 

Table 60: Share of domestic European works for the VoD providers with the largest share of European 
works per target country  

Country 

VoD Provider 

Domestic as % 
of EW 

Country 

VoD Provider 

Domestic as % 
of EW 

Amazon Video 

VOD Club 

Apple TV 

Google Play 
Movies 
Sooner 

Sooner 

Apple TV 

Google Play 
Movies 
Telenet 

Yelo Play 

HBO Max 

Netflix 

Apple TV 

DocAlliance 
Films 
Nova Play 

DocAlliance 
Films 
Apple TV 

Netflix 

Google Play 
Movies 
HBO Max 

Amazon Video 

Google Play 
Movies 
YouTube 

Apple TV 

MagentaTV 

Blockbuster 

Apple TV 

Austria 

Belgium 

Bulgaria 

Czechia 

Germany 

Denmark 

Hungary 

5% 

83% 

5% 

3% 

13% 

32% 

8% 

11% 

Ireland 

46% 

48% 

5% 

1% 

0% 

1% 

64% 

25% 

8% 

7% 

14% 

21% 

43% 

47% 

46% 

37% 

48% 

30% 

18% 

Italy 

Lithuania 

Latvia 

Netherlands 

Netflix 

Horizon 

HBO Max 

Apple TV 

YouTube 

Apple TV 

Google Play 
Movies 
Sky Store 

Rakuten TV 

Volta 

Chili 

Amazon Video 

Apple TV 

Google Play 
Movies 
Rai Play 

Telia Play 

Go3 

DocAlliance 
Films 
Apple TV 

GuideDoc 

Go3 

DocAlliance 
Films 
Apple TV 

GuideDoc 

True Story 

Apple TV 

Videoland 

2% 

10% 

6% 

1% 

2% 

4% 

4% 

5% 

5% 

24% 

49% 

44% 

33% 

36% 

79% 

17% 

31% 

2% 

0.1% 

1% 

15% 

2% 

0.4% 

1% 

2% 

13% 

54% 

258 

 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country 

VoD Provider 

Domestic as % 
of EW 

Country 

VoD Provider 

Domestic as % 
of EW 

Google Play 
Movies 
SF Anytime 

Filmstriben 

Go3 

DocAlliance 
Films 
Apple TV 

GuideDoc 

Netflix 

FlixOlÃ© 

Filmin 

FlixOlÃ© 
Amazon Channel 
Amazon Prime 
Video 
Rakuten TV 

Yle Areena 

Viaplay 

SF Anytime 

Telia Play 

Elisa Viihde 

Orange VOD 

Universcine 

Apple TV 

Canal VOD 

Google Play 
Movies 
Apple TV 

Google Play 
Movies 
DocAlliance 
Films 
Netflix 

Filmzie 

Estonia 

Spain 

Finland 

France 

Greece 

23% 

18% 

33% 

19% 

1% 

KPN 

Google Play 
Movies 
Pathé Thuis 

NRK TV 

Apple TV 

0.3% 

Norway 

SF Anytime 

1% 

0.1% 

85% 

33% 

86% 

31% 

21% 

70% 

16% 

10% 

10% 

19% 

69% 

69% 

55% 

65% 

54% 

1% 

1% 

1% 

0.1% 

1% 

Poland 

Portugal 

Romania 

Sweden 

Strim 

TV 2 Play 

Horizon 

Player 

Netflix 

Chili 

VOD Poland 

Meo 

Filmin 

RTPplay 

DocAlliance 
Films 
HBO Max 

Netflix 

Horizon 

HBO Max 

DocAlliance 
Films 
Amazon Prime 
Video 
SF Anytime 

Cineasterna 

Apple TV 

Viaplay 

Google Play 
Movies 

26% 

15% 

23% 

63% 

9% 

11% 

25% 

23% 

23% 

24% 

9% 

16% 

10% 

14% 

14% 

67% 

6% 

11% 

3% 

8% 

8% 

2% 

3% 

26% 

32% 

12% 

20% 

17% 

Source: JustWatch 

Table 61: Share of domestic European works for the VoD providers with the largest share of European 
works per target country (second definition) 

Country 

VoD Provider 

Domestic as % 
of EW 

Country 

VoD Provider 

Domestic as % 
of EW 

Austria 

 Amazon Video  

 VOD Club  

 Apple TV  

Google Play     
Movies  
 Sooner  

2% 

49% 

2% 

1% 

9% 

Hungary 

Netflix 

Horizon 

HBO Max 

Apple TV 

YouTube 

2% 

8% 

5% 

0% 

0% 

259 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country 

VoD Provider 

Domestic as % 
of EW 

Country 

VoD Provider 

Domestic as % 
of EW 

Belgium 

Bulgaria 

Czechia 

Germany 

Denmark 

Estonia 

Spain 

Finland 

 Sooner  

 Apple TV  

 Google Play 
Movies  
 Telenet  

 Yelo Play  

 HBO Max  

 Netflix  

 Apple TV  

 DocAlliance 
Films  
 Nova Play  

 DocAlliance 
Films  
 Apple TV  

 Netflix  

 Google Play 
Movies  
 HBO Max  

 Amazon Video  

 Google Play 
Movies  
 YouTube  

 Apple TV  

 MagentaTV  

 Blockbuster  

 Apple TV  

 Google Play 
Movies  
 SF Anytime  

 Filmstriben  

 Go3  

 DocAlliance 
Films  
 Apple TV  

 GuideDoc  

 Netflix  

 FlixOlÃ©  

 Filmin  

 FlixOlÃ© 
Amazon Channel  
 Amazon Prime 
Video  
 Rakuten TV  

 Yle Areena  

 Viaplay  

 SF Anytime  

14% 

2% 

3% 

Ireland 

36% 

38% 

4% 

0.4% 

0.2% 

0.5% 

64% 

15% 

4% 

4% 

8% 

12% 

30% 

32% 

30% 

23% 

34% 

24% 

13% 

17% 

12% 

23% 

14% 

0.2% 

Italy 

Lithuania 

Latvia 

Netherlands 

Apple TV 

Google Play 
Movies 
Sky Store 

Rakuten TV 

Volta 

Chili 

Amazon Video 

Apple TV 

Google Play 
Movies 
Rai Play 

Telia Play 

Go3 

DocAlliance 
Films 
Apple TV 

GuideDoc 

Go3 

DocAlliance 
Films 
Apple TV 

GuideDoc 

True Story 

Apple TV 

Videoland 

KPN 

Google Play 
Movies 
PathÃ© Thuis 

NRK TV 

Apple TV 

0.1% 

Norway 

SF Anytime 

1% 

0% 

63% 

25% 

63% 

24% 

14% 

63% 

12% 

6% 

Poland 

Portugal 

Strim 

TV 2 Play 

Horizon 

Player 

Netflix 

Chili 

VOD Poland 

Meo 

Filmin 

RTPplay 

2% 

1% 

2% 

1% 

13% 

36% 

30% 

23% 

25% 

60% 

12% 

22% 

1% 

0.0% 

0% 

11% 

1% 

0.1% 

1% 

1% 

9% 

46% 

19% 

10% 

16% 

59% 

6% 

7% 

21% 

18% 

21% 

20% 

8% 

12% 

7% 

10% 

7% 

65% 

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Country 

VoD Provider 

Domestic as % 
of EW 

Country 

VoD Provider 

Domestic as % 
of EW 

 Telia Play  

 Elisa Viihde  

 Orange VOD  

 Universcine  

 Apple TV  

 Canal VOD  

 Google Play 
Movies  
 Apple TV  

 Google Play 
Movies  
 DocAlliance 
Films  
 Netflix  

 Filmzie  

France 

Greece 

7% 

15% 

42% 

39% 

32% 

35% 

30% 

0.2% 

0.2% 

0.2% 

0.0% 

0.5% 

Romania 

Sweden 

DocAlliance 
Films 
HBO Max 

Netflix 

Horizon 

HBO Max 

DocAlliance 
Films 
Amazon Prime 
Video 
SF Anytime 

Cineasterna 

Apple TV 

Viaplay 

Google Play 
Movies 

4% 

7% 

2% 

6% 

5% 

1% 

2% 

19% 

23% 

7% 

13% 

10% 

Source: JustWatch 

5.2.6     Recent European works 

In this section, we defined as recent all European works released in 2017 or later, meaning these productions 
were maximum five years old at the time of the analysis. Across the 1 062 catalogues, there were in total 719 
223 European works (according to the first definition) and 569 207 European works (according to the second 
definition) of which 222 438 were released in 2017 or later. 

As shown below, looking at the country distribution, we observe that Germany (29 127), France (24 708), and 
Austria (19 149) have the most absolute numbers of recent European works. On the other hand, Romania has 
the least absolute number of recent European works (2 794). 

Table 62: Number of recent European works by target country (released 2017 or later) 

Country 

No of recent European movies  No of recent European series 

No of recent European works 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

17 051  

 8 305  

 2 723  

 3 569  

 25 741  

 10 192  

 2 964  

 8 781  

 11 318  

 22 179  

 2 407  

 3 392  

 2 098  

 791  

 673  

 632  

 3 386  

 1 711  

 697  

 1 643  

 1 447  

 2 529  

 553  

 644  

19 149  

 9 096  

 3 396  

 4 201  

 29 127  

 11 903  

 3 661  

 10 424  

 12 765  

 24 708  

 2 960  

 4 036  

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Country 

No of recent European movies  No of recent European series 

No of recent European works 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

 10 325  

 11 021  

 3 221  

 2 867  

 11 109  

 11 617  

 6 062  

 3 834  

 2 140  

 11 868  

Total 

 192 686  

Source: JustWatch 

5.2.7     Independent productions 

 1 847  

 1 594  

 727  

 705  

 1 625  

 2 245  

 1 199  

 800  

 654  

 1 552  

 29 752  

 12 172  

 12 615  

 3 948  

 3 572  

 12 734  

 13 862  

 7 261  

 4 634  

 2 794  

 13 420  

 222 438  

To identify European independent productions, we used the members of the following associations: 

•  The European Audiovisual Production association350 

•  EuroVoD351 

•  European Producers Club (EPC)352 

We considered as a European independent production any production which had at least one of the companies 
as  members  of  these  associations.  The  identification  of  independent  productions  therefore  only  covers 
European independent production companies for the purposes of this section of the study.  

As  with  linear  services,  this  approach  is  very  much  dependent  on  constructing  a  comprehensive  list  of 
European independent producers and production companies. Despite the extensive effort invested in creating 
an exhaustive list of independent production companies from Europe, it is inevitable that some of them may 
have been inadvertently omitted. Additionally, during the fuzzy matching between the names of independent 
production companies from JustWatch’s database and the compiled list, the presence of significant different 
names could have results in failure to find a matching pair.  

As mentioned in the methodology section too, for the previous study conducted in 2020-2021, there was an 
important gap in the data, which only allowed us to present this analysis for a fraction of the VoD services. 
JustWatch does not have data on production companies for films, but only TV series. Thus, it was not feasible 
to match this movie data with a list of major or independent production companies.  As explained earlier, series 
represent only a small share of the catalogues, considering that one season is counted as one production.  

Therefore, the data used in the previous study only concerned TV series and we could not extrapolate the 
findings to the entire catalogues (films + TV series). However, for the current study, the films from JustWatch’s 
database were matched against the IMDb list of titles to retrieve the names of the production companies for 

350 https://www.cepi-producers.eu/our-members 

351 https://www.euroVoD.org/members 

352 https://www.europeanproducersclub.org/members 

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the missing productions. This way, the indicator on the share of European independent productions is robust 
and therefore we can extrapolate the findings to the entire catalogues.  

The figure below shows that most of the services had between 6.1% and 9% of European works that were 
produced by European independent companies.  

There  are  some  services  in  the  sample  which  had  a  relatively  high  share  of  works  with  participation  of 
independent producers, these are: 

•  RTPPlay  (PT)  –  of  the  147  European  works,  45  had  a  participation  from  independent  producers 

(30.6%)  

•  France TV (FR) – 37 out of the 129 European works had participation from independent producers 

(28.7%) 

•  Rakuten Viki (DE, MT, SI) – where around 33.3% of works were European works with independent 
participation of full funding. However, this percentage is rather high due to having a very low number 
of European works in the catalogue, in the first place. For example, in Germany, Rakuten Viki has 4 
European works and 2 of them are European independent productions.  

Generally, most VoD services have between 0.1% and 11% of European independent productions (in total, 
786), with most of them falling in the 6.1% to 9% bucket (in total, 227). The graph below shows a clear decrease 
in the number of services with more than 11% of European independent productions.  

Figure 82: European independent works as a share of total European works – distribution of services 
according to intervals (groupings) 

5.2.8     European works by genre 

The analysis of productions in VoD catalogues by genre follows the classification of JustWatch into genres 
which differentiates between granular categories.  

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Figure 83: Share of European works in all catalogues analysed by genre (movies and series combined) 

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Figure 84: Share of European works in all catalogues analysed by genre (movies only) 

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Figure 85: Share of European works as part of only films by country 

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5.2.9     Comparison with Member State data 

The  share  of  European  works  in  VoD  catalogues  as  determined  in  the  JustWatch  database  has  been 
compared with the data that national authorities have reported in relation to Art. 13 (1) of the AVMSD353. There 
are significant disparities between the two data sets, as national authorities report data on VoD services that 
are  within  their  jurisdiction,  which  tend  to  only  include  smaller  local  VoD  services,  while  the  JustWatch 
database  tends  to  include  larger  international  VoD  services,  thus  there  is  a  mismatch  in  the  types  of  VoD 
services  each  database  catches  and  the  number  of  matches  between  the  two  databases  is  rather  limited. 
Indeed, the larger international services like Netflix and Amazon Prime are only reported in one EU Member 
State in the national authority reports (the country of jurisdiction) whereas they are reported in all countries in 
the JustWatch database, so the comparison could only be made in the country of jurisdiction.  Furthermore, 
some  national  authorities  reported  data  from  previous  years  and  some  did  not  report  on  VoD  shares  of 
European works, thus adding to the reasons why only few comparisons could be made. The below table shows 
the shares of European works as determined by the two sources of the matched VoD services.  

Table 63: Shares of European works of matched VoD services 

Country 

VoD Name 

Share of European 
works (Member 
State) 

Share of European 
works (JustWatch) 

Difference 

AT 

BE 

CZ 

EE 

ES 

FI 

FR 

MagentaTV 

VOD Club 

Sooner 

VRT MAX 

DocAlliance Films 

HBO Max 

O2 TV 

Go3 

AcornTV 

Atres Player 

Filmin 

Mitele  

Movistar Plus 

Planet Horror 

Rakuten TV 

rtve 

TVCortos 

C More 

Elisa Viihde 

Ruutu 

Yle Areena 

Action Max 

Arte 

Benshi 

Canal VOD 

Canal+ Series 

Canal+ 

Cinemas a la 
Demande 

20% 

98% 

74% 

86% 

74% 

36% 

38% 

32% 

83% 

71% 

59% 

92% 

39% 

32% 

35% 

98% 

44% 

64% 

33% 

80% 

88% 

27% 

89% 

89% 

67% 

62% 

77% 

64% 

19% 

94% 

69% 

64% 

64% 

32% 

25% 

25% 

83% 

43% 

53% 

93% 

33% 

27% 

26% 

88% 

38% 

58% 

29% 

31% 

85% 

25% 

81% 

77% 

49% 

40% 

52% 

48% 

353 With the exception of Germany 

-1% 

-4% 

-5% 

-22% 

-10% 

-4% 

-13% 

-7% 

0% 

-28% 

-6% 

1% 

-6% 

-5% 

-9% 

-10% 

-6% 

-6% 

-4% 

-49% 

-3% 

-2% 

-8% 

-12% 

-18% 

-22% 

-25% 

-16% 

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Country 

VoD Name 

Share of European 
works (Member 
State) 

Share of European 
works (JustWatch) 

Difference 

FILMO 

France TV 

INA madelen 

LaCinetek 

MyTF1VoD 

OCS Go 

Shadowz 

Tenk 

Universcine 

HRTi 

Pickbox NOW 

RTL Play 

Chili 

Discovery Plus 

Infinity+ 

Rai Play 

Timvision 

Telia Play 

CineMember 

Discovery Plus 

Disney Plus 

Film1 

IFFR Unleashed 

KPN 

meJane 

Netflix 

Pathe Thuis 

Picl 

Ziggo TV 

Canal+ 

Player 

Meo 

SVT 

C More 

HBO Max 

Viaplay 

Filmzie 

Voyo 

65% 

89% 

100% 

61% 

51% 

61% 

68% 

91% 

62% 

56% 

66% 

67% 

34% 

31% 

54% 

53% 

37% 

38% 

52% 

18% 

12% 

48% 

34% 

100% 

39% 

23% 

28% 

79% 

33% 

59% 

88% 

32% 

91% 

66% 

32% 

37% 

40% 

59% 

57% 

69% 

97% 

51% 

0% 

57% 

45% 

79% 

58% 

75% 

33% 

38% 

41% 

29% 

57% 

76% 

34% 

28% 

68% 

13% 

12% 

34% 

44% 

32% 

27% 

38% 

29% 

60% 

36% 

100% 

38% 

34% 

83% 

66% 

30% 

29% 

19% 

41% 

-8% 

-20% 

-3% 

-10% 

-51% 

-4% 

-23% 

-12% 

-4% 

19% 

-33% 

-29% 

7% 

-2% 

3% 

23% 

-3% 

-10% 

16% 

-5% 

0% 

-14% 

10% 

-68% 

-12% 

15% 

1% 

-19% 

3% 

41% 

-50% 

2% 

-8% 

0% 

-2% 

-8% 

-21% 

-18% 

HR 

IT 

LT 

NL 

PL 

PT 

SE 

SK 

Broadly, we see that the share of European works as calculated in the JustWatch database tends to be slightly 
lower than the share of European works reported by the national authorities. One reason why this might be is 
how European works are calculated. Within the Member State reporting, there is no mention how a European 
work  is  determined,  which  may  vary  from  our  stringent  definition  of  a  European  work  (when  a  majority  of 
production companies are European). Although we see several VoD services where the share of European 

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works is higher in the JustWatch database than reported by national authorities, two countries stand out in this 
regard. In particular, out of the five matched VoD services in Italy, three have higher European shares in the 
JustWatch  database  and  of  the  11  matched  VoD  services  in  the  Netherlands,  five  have  higher  European 
shares in the JustWatch database. For the Netherlands, this difference may be explained by the fact that, while 
most national authorities reported data as of 2021, the Dutch national authority had only reported data from 
2020. As such, the reporting by the Member States would presumably be outdated and VoD services would 
have increased the share of European works within their catalogues since last reported. Furthermore, both the 
Netherlands  and  Italy  had  transposed  Art.  13  (1)  of  the  AVMSD  obligating  on-demand  audiovisual  media 
services to secure at least a 30 % share of European works and ensuring prominence within the reference 
period.  It  is  therefore  reasonable  to  assume  that  the  higher  shares  of  European  works  in  the  JustWatch 
database  in  comparison  with  the  shares  reported  by  the  national  authorities  to  be  a  result  of  these 
transpositions.  

Given the reporting of European works is to be completed by the national authority of the country of jurisdiction, 
a secondary analysis was done to determine whether shares of European works for larger international VoD 
services were higher in the country of jurisdiction compared to the other countries. The below table shows the 
shares of European works for Netflix, Amazon Prime, Apple TV+, and Disney+ for the available countries in 
the JustWatch database. The country of jurisdiction for each service is bolded and underlined. 

Table 64: Shares of European works for larger international VoD services 
Apple TV+ 

Amazon Prime 

Country 

Netflix 

Albania 

Andorra 

Austria 

Belgium 

Bosnia and 
Herzegovina 
Bulgaria 

Croatia 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Great Britain 

Greece 

Hungary 

Iceland 

Ireland 

Italy 

Latvia 

Liechtenstein 

Lithuania 

Malta 

Moldova 

Monaco 

Netherlands 

North Macedonia 

Norway 

Poland 

21% 

22% 

36% 

34% 

21% 

40% 

47% 

47% 

37% 

40% 

38% 

34% 

37% 

31% 

42% 

41% 

39% 

30% 

38% 

40% 

24% 

40% 

28% 

23% 

19% 

38% 

21% 

39% 

37% 

17%  X 

25%  X 

41% 

35% 

16%  X 

28% 

30%  X 

28% 

24% 

30% 

23% 

37% 

41% 

24% 

29% 

30% 

16%  X 

23% 

44% 

32% 

30%  X 

30% 

25%  X 

20%  X 

31%  X 

32% 

17%  X 

24% 

26% 

Disney+ 

14% 

14% 

14% 

13% 

14% 

14% 

14% 

13% 

14% 

14% 

13% 

13% 

14% 

14% 

13% 

14% 

14% 

14% 

14% 

X 

X 

7% 

13% 

14% 

12% 

7% 

7% 

7% 

7% 

10% 

7% 

11% 

9% 

14% 

12% 

8% 

6% 

9% 

12% 

12% 

7% 

13% 

7% 

8% 

12% 

7% 

10% 

8% 

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Portugal 

Romania 

San Marino 

Serbia 

Slovakia 

Slovenia 

Spain 

Sweden 

Switzerland 

Turkey 

41% 

43% 

22% 

21% 

40% 

38% 

40% 

38% 

36% 

23% 

29% 

29%  X 

47%  X 

17%  X 

31% 

28% 

38% 

24% 

34% 

25%  X 

14% 

13% 

14% 

14% 

14% 

14% 

10% 

7% 

12% 

7% 

7% 

7% 

13% 

11% 

13% 

13% 

For Disney+ and Apple TV+, the shares of European works fluctuate very little between country. For Apple 
TV+ it ranges between 13-14% and for Disney+ it is between 6% and 14%. In comparison with Netflix, it ranges 
from 19% to 47% and with Amazon Prime it goes from 16% to 47%. Given the consistency of the share of 
European works by country, we can assume that the catalogue does not differ too greatly with Disney+ and 
Apple TV+ and thus the country of jurisdiction will not have a higher share of European works. For Netflix, the 
country of jurisdiction (the Netherlands) is not among the highest with regards to the share of European works, 
while for Amazon Prime, the country of jurisdiction (Germany) is fourth highest only behind Austria, Italy  and 
San  Marino.  While  Amazon  Prime  does  indeed  have  a  high  share  of  European  works  in  its  country  of 
jurisdiction, there is no clear trend in these values that cannot be explained by, for example the robustness of 
domestic film industries.  

5.3     Non-linear services – methods to ensure prominence  

5.3.1     Summary of the methodology 

The aim of this chapter is to present the main prominence methods used by non-linear services. To this aim, 
two analyses were planned. Firstly, a mystery shopping exercise which involves analysing four SVoDs for 15 
EU Member States to understand to what extent SVoD services ensure visibility of European and EU27 works. 
Secondly,  the  data  collected  through  the  mystery  shopping  exercise  would  subsequently  be  linked  to  the 
popularity index developed by Ampere Analysis.  

Lastly, the results of the mystery shopping were discussed with stakeholders who provided feedback on the 
prominence methods. These are presented at the end of the chapter.  

5.3.2     Assessment of prominence methods 

This  chapter  also includes  the results of the  mystery shopping  exercise. Specifically, this report details our 
analysis on the following areas within the SVoD services: 

−  availability of European and domestic works or the ability for users to quickly find European or domestic 

works 

−  advertising of European and domestic works 

− 

functionalities of the SVoD services 

−  visibility of European and domestic works  

−  qualitative inputs from mystery shoppers 

This chapter examines these factors on a country-level basis and on a service-level basis to provide insight 
from the comparisons.  

Indeed, the differences in the results show these indicators may be due to the service selection by country. 
For  example,  there  are  no  local  services  for  Czechia,  Slovakia,  and  Denmark  whereas  there  are  two  local 
services for Poland, the Netherlands, Sweden, and  Spain, which can cause disparities in the country  level 
results.  Therefore,  it  is  important  to  also  include  a  comparison  between  different  services.  International 
services may have larger catalogues and more resources to include further functionalities into their services. 
We include service-level comparison on the five services that appear in three or more countries in the analysis 

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(Netflix – 14 countries, Amazon Prime – 10 countries, Mubi – 5 countries, Disney+ – 3 countries, and Voyo – 
3 countries). 

Availability of European and domestic works 

The  mystery  shopping  exercise  aimed  to  determine  how  well  European  works  are  readily  available  to  be 
viewed by the user, for example through specific sections on the front page with European works or through 
search results for European works. This is distinct from the total share of European and domestic works in the 
SVoD catalogues and is measured through several indicators. The results show that 40% of services include 
separate sections on the homepage for European works and works from the targeted country. When examining 
country  differences,  Austria  has  the  highest  share  of  services  with  such  sections  on  the  homepage  and 
Hungary has the lowest share (75% and 0% respectively). It is unlikely that this difference is due to international 
SVoDs as they largely have the same approach in every country. Specifically, the prominence methods used 
by international SVoDs will likely be the same between countries. Therefore, these differences by country are 
more likely due to the make up of local and international SVoDs and local SVoDs being more or less active in 
promoting European works and making them more available. Another factor that may also contribute to this 
disparity  is  the  size  of  the  internal  TV  and  film  industry  as  SVoDs  from  larger  countries  may  have  more 
domestic  productions  to  include  into  their  catalogues.  An  important  measure  of  availability  is  whether  the 
service provides results for European works or works from the targeted country when searching in the search 
bar. We found that 46% of services across all countries would provide search results for European works and 
41% of services would provide search results for works from the targeted country. This disparity is likely due 
to smaller countries with less robust film and TV industries being under-represented in the catalogues of SVoD 
services and thus services are unable to offer the ability to search for these works. Austria, Belgium, and Spain 
have the highest shares of services providing these search results and Hungary has the lowest share (75% 
and 0% respectively). The shares are lower when accounting for the secondary definition of European and 
EU27 works (where the majority of production companies are from the indicated region). 

Further, the exercise investigated the share of services that offered the ability to filter titles of specific countries 
or  regions  through  categories.  This  measure  did  not  look  at  whether  there  existed  a  ‘European’  category 
specifically,  but  rather  whether  it  was  possible  to  filter  titles  through  country  or  region  categories.  49%  of 
services had specific country or region categories with the  highest share in  Austria (100%) and the lowest 
share in Slovakia (0%). Again, the practices of local SVoDs are more relevant in creating these differences. 

Regarding the five SVoD services that appear three or more times in the analysis,  we find that 90% of the 
Amazon Prime and 86% of Netflix home pages included a European section whereas this was never present 
for Voyo, Disney+, or Mubi. However, Voyo always included a section of works from the targeted country, but 
this was never present for Mubi. Netflix had the highest share of services where one could search for European 
works and works from the targeted country at 100% and 79% respectively. These functionalities were again 
never present for Mubi. For Amazon Prime these shares were 80% and 70%. Netflix included categories for 
specific countries and regions 79% of the time, but Disney+ and Voyo only had these categories one third of 
the time. Local services generally had lower shares for the indicators except that nearly half of the services 
had a designated section for domestic works and had country and region categories. Indeed, local services 
may implement fewer prominence methods than international services. 

The search bar is a main way for users to find content on SVoDs. As such the share of European and domestic 
works from the results are an important measure of availability. When searching for European works in the 
search bar, we see 91% of suggested titles are European, 75% are EU27 works, 18% are domestic works and 
16%  are UK works. When  searching for domestic works, unsurprisingly, 81% of  titles are indeed domestic 
productions. Furthermore, SVoD services in France, Germany, Poland, and Spain tend to have higher shares 
for domestic productions whereas there are lower shares in Estonia, Hungary, Belgium, and Austria. These 
values are expected as SVoDs from larger countries with larger domestic film and TV industries are able to 
include more domestic works in their catalogues. With regards to the countries with smaller shares, we believe 
there  to  be  two  factors  at  play.  Firstly,  smaller  countries  like  Estonia  and  Hungary  have  smaller  domestic 
industries, and secondly, countries like Belgium and Austria who share languages with other larger European 
nations (French, Dutch, and German for Belgium and German for Austria) may be reliant on other nations’ film 
and TV industries. With regards to service level search bar results, Disney+ suggested European works less 
than other platforms, except for when searching for domestic works. Netflix also performed better than other 
platforms when searching for both European and domestic works. Netflix seems to approach the prominence 
of European works through user input. 

The titles that are shown in the dedicated ‘European’ section within the service is an important indicator of 
availability.  Country-level  results  show  that  all  countries  have  high  levels  of  European  works  (these  range 

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works in audiovisual media services 

between 72% and 95%). EU27 works are also widely available, but this varies more compared to European 
works (between 40% and 92%). Overall, availability of domestic works is low compared to European or EU27 
works (between 0% and 50%). Sweden and Estonia report 0% domestic works for the period when the mystery 
shopping was conducted, while Czechia, Romania, France and Spain have the highest shares of domestic 
works (49-50%). An overwhelming majority of titles from Voyo were European, from EU27 or domestic (99%, 
99% and 92% respectively). On Prime and Netflix, in general the availability of European works indicators in 
the mystery shopping exercise were over 80% and over 70% on local services. Most UK works were available 
on Netflix (40%) and Prime (31%). 

272 

 
 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 65: Country-level availability results 

AT 

BE 

CZ 

DK 

EE 

FR 

DE 

HU 

IT 

NL 

PL 

RO 

SK 

ES 

SE 

Total 

European works section 

Domestic works section 

Ability to search for European works 

Ability to search for domestic works 

Country or region categories 

Search results for European content 

Search results for European content 
(different definition) 
Search results for domestic content 

Search results for domestic content 
(different definition) 
European section 

European section (different definition) 

European 
works 

Search results for European content 

EU27 works 

Search results for European content 
(different definition) 
Search results for domestic content 

Search results for domestic content 
(different definition) 
European section 

European section (different definition) 

Search results for European content 

Search results for domestic content 

Domestic 
works 

European section 

Search results for European content 

UK works 

Search results for domestic content 

European section 

75% 

75% 

75% 

75% 

100% 

93% 

87% 
93% 

90% 
93% 

65% 
80% 

73% 
90% 

87% 
68% 

44% 
3% 

57% 

2% 

10% 

7% 

20% 

75% 

25% 

75% 

75% 

50% 

90% 

70% 
86% 

86% 
93% 

60% 
80% 

53% 
89% 

86% 
70% 

45% 
13% 

77% 

29% 

17% 

10% 

30% 

25% 

50% 

25% 

50% 

25% 

50% 

50% 
70% 

70% 
92% 

74% 
30% 

15% 
60% 

60% 
82% 

63% 
0% 

50% 

50% 

10% 

5% 

12% 

25% 

25% 

25% 

25% 

25% 

90% 

25% 

25% 

25% 

0% 

75% 

50% 

75% 

50% 

50% 

50% 

40% 

40% 

60% 

60% 

40% 

0% 

0% 

0% 

0% 

25% 

50% 

50% 

50% 

50% 

75% 

50% 

50% 

25% 

50% 

25% 

100% 

100% 

100% 

X 

100% 

100% 

50% 

75% 

25% 

25% 

75% 

90% 

25% 

25% 

75% 

0% 

50% 

83% 

25% 

25% 

75% 

50% 

0% 

93% 

83% 
100% 

X 

90% 

90% 
100% 

72% 
100% 

X 
X 

100% 
89% 

X 
83% 

64% 
70% 

70% 

90% 

50% 
85% 

60% 
80% 

87% 
88% 

X 
93% 

61% 
67% 

78% 
X 

60% 
100% 

X 

70% 

80% 
100% 

65% 
100% 

X 
X 

100% 
58% 

X 
45% 

45% 
10% 

35% 

0% 

100% 
40% 

15% 
50% 

87% 
66% 

X 
62% 

46% 
36% 

53% 
X 

100% 

X 

100% 

97% 

X 

32% 

10% 

10% 

10% 

0% 

X 

28% 

33% 

0% 

25% 

0% 

60% 

49% 

49% 

40% 

0% 

X 

X 

29% 

29% 

70% 
75% 

75% 
X 

X 
90% 

90% 
70% 

30% 
X 

X 
5% 

70% 

X 

27% 

5% 

X 

89% 
95% 

65% 
91% 

68% 
70% 

57% 
90% 

54% 
68% 

50% 
10% 

75% 

36% 

30% 

5% 

28% 

50% 
100% 

80% 

X 

83% 
70% 

85% 
95% 

X 
85% 

64% 
80% 

52% 

77% 

14% 
72% 

47% 
77% 

50% 
100% 

77% 

X 

77% 
70% 

80% 
51% 

X 
47% 

29% 
10% 

20% 

43% 

100% 

X 

25% 

13% 

10% 

0% 

0% 

X 

44% 

49% 

14% 
72% 

47% 
20% 

65% 

50% 

10% 

0% 

0% 

50% 

50% 

75% 

75% 

50% 

82% 

82% 
90% 

90% 
90% 

65% 
73% 

73% 
87% 

87% 
45% 

20% 
26% 

83% 

0% 

7% 

0% 

60% 

39% 

41% 

46% 

41% 

49% 

91% 

77% 
90% 

76% 
88% 

62% 
75% 

66% 
88% 

74% 
59% 

39% 
18% 

81% 

25% 

16% 

3% 

33% 

25% 

25% 

25% 

25% 

75% 

100% 

87% 
100% 

100% 
77% 

43% 
80% 

77% 
100% 

100% 
47% 

31% 
20% 

100% 

1% 

20% 

0% 

34% 

273 

 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 66: Service level availability results (all local services aggregated) 

Voyo 

Disney+ 

Mubi 

Prime 

Netflix 

Local 

European works section 

Domestic works section 

Ability to search for European works 

Ability to search for domestic works 

Country or region categories 

Search results for European content 

European works 

Search results for European content  
(different definition) 
Search results for domestic content 

Search results for domestic content  
(different definition) 
European section 

European section (different definition) 

Search results for European content 

EU27 works 

Search results for European content  
(different definition) 
Search results for domestic content 

Search results for domestic content  
(different definition) 
European section 

European section (different definition) 

Search results for European content 

Domestic works 

Search results for domestic content 

European section 

Search results for European content 

UK works 

Search results for domestic content 

European section 

0% 

0% 

0% 

0% 

40% 

0% 

100% 

67% 

67% 

33% 

100% 

X 

X 

100% 
70% 

70% 
99% 

78% 
85% 

85% 
70% 

60% 
99% 

78% 
75% 

65% 

92% 

X 

X 

X 

5% 

X 

0% 

2% 

0% 

67% 

0% 

33% 

33% 

100% 

100% 
X 

X 

100% 

100% 
X 

X 

100% 

X 

0% 

X 

X 

X 
X 

X 
X 

X 
X 

X 
X 

X 
X 

X 
X 

X 

X 

X 

X 

X 

90% 

50% 

80% 

70% 

50% 

82% 

68% 
81% 

78% 
88% 

62% 
70% 

55% 
80% 

77% 
62% 

47% 
21% 

63% 

30% 

19% 

3% 

31% 

86% 

29% 

100% 

79% 

79% 

94% 

81% 
93% 

88% 
89% 

66% 
76% 

72% 
90% 

86% 
51% 

30% 
12% 

86% 

13% 

15% 

2% 

40% 

6% 

44% 

13% 

13% 

44% 

89% 

89% 
100% 

95% 
72% 

40% 
64% 

61% 
95% 

95% 
72% 

40% 
36% 

95% 

43% 

31% 

0% 

7% 

274 

 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Advertising of European and domestic works 

Of  the  advertising  measures  on  prominence  of  European  works,  the  analysis  investigates  the  banners, 
advertisements, or posters on the home page. 

Among banners and advertisements in all countries, 52% are European works, 35% are EU27 works, 21% are 
domestic works and 16% are UK works. The share of European works is highest in Sweden (85%) and lowest 
in  Romania  and  Italy  (both  35%).  The  extent  that  there  are  differences  between  countries  on  how  visible 
European  works  are  made  are  perhaps  again  likely  due  to  the  catalogues  of  local  SVoDs  or  how  reliant 
services are on international works.  

Regarding platform-level results, generally Voyo, Netflix, and Amazon Prime promoted European works more 
than Mubi and Disney+. Mubi only promoted European works through banners and advertisements with 52% 
being European and 0% being domestic works. 

275 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 67: Country-level advertising results 

Share of works in 
advertisements and 
banners % 
AT 
BE 
CZ 
DK 
EE 
FR 
DE 
HU 
IT 
NL 
PL 
RO 
SK 
ES 
SE 
Total 

European Works 

European Works 
(different 
definition) 

EU27 Works 

EU27 Works 
(different 
definition) 

Domestic Works 

UK Works 

80% 
40% 
45% 
40% 
45% 
49% 
55% 
40% 
35% 
60% 
77% 
35% 
45% 
45% 
85% 
52% 

60% 
30% 
40% 
40% 
40% 
40% 
45% 
35% 
33% 
20% 
51% 
30% 
25% 
40% 
38% 
38% 

50% 
25% 
20% 
20% 
29% 
25% 
48% 
27% 
20% 
55% 
37% 
25% 
30% 
45% 
74% 
35% 

28% 
25% 
15% 
13% 
20% 
25% 
40% 
25% 
20% 
15% 
32% 
21% 
25% 
13% 
30% 
23% 

20% 
5% 
0% 
0% 
13% 
25% 
48% 
0% 
20% 
45% 
37% 
25% 
0% 
40% 
38% 
21% 

Table 68: Service-level advertising results (all local services aggregated) 

Share of works in  
advertisements and banners % 

European Works 

European Works 
(different 
definition) 

EU27 Works 

EU27 Works 
(different 
definition) 

Domestic Works  UK Works 

Voyo 
Disney+ 
Mubi 
Prime 
Netflix 
Local 

67% 
53% 
52% 
48% 
31% 
76% 

67% 
47% 
52% 
24% 
31% 
73% 

67% 
20% 
36% 
22% 
9% 
69% 

67% 
20% 
36% 
12% 
9% 
68% 

33% 
20% 
0% 
14% 
7% 
56% 

40% 
15% 
30% 
15% 
10% 
25% 
8% 
13% 
10% 
5% 
40% 
5% 
15% 
5% 
5% 
16% 

0% 
27% 
16% 
26% 
23% 
7% 

276 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Functionalities of the SVoD services 

Within the functionality of the services, we examine the existence of a ‘Recommended’ section, an ‘Autoplay’ 
function, and a ‘Similar’ section under titles. 75% of services suggest other titles as ‘similar’ when selecting a 
title,  62%  of  services  include  a  ‘Recommended’  section  on  the  home  page,  and  42%  of  services  have  an 
‘Autoplay’ function (after a title is finished, a new title is either suggested or played). 

Regarding the functionalities of SVoD services, we find that Voyo  and  Mubi would always suggest ‘similar’ 
titles, but this was the case for Disney+ only two thirds of the time. Amazon Prime and Voyo would always 
include a ‘recommended’ section, but this was never present for Mubi. Netflix includes an ‘Autoplay’ function 
86% of the time, but this is never present for Mubi. Local services generally have fewer functionalities than the 
international services. 

The functionality indicators also examine the shares of European and domestic works within these areas. In 
the similar title sections, autoplay functions, and recommended titles sections, approximately 35% of titles are 
European works, 25% are EU27 works, 15% are domestic works, and 10% are  UK works. Indeed, without 
user input to induce personalised offers of European works, the service will instead suggest markedly lower 
shares of European and domestic works (from 80-90% to 20-30%). When looking at the shares of UK works, 
SVoD services in Germany and France have the highest share of suggested UK works and Romania has the 
lowest. The availability of subtitles of UK works to the native language may be greater for larger countries and 
thus  may  be  reason  for  higher  shares  of  UK  works  in  Germany  and  France.  Broadly,  when  looking  at  the 
secondary definition of European and EU27 works, we see a general trend of lower shares among all countries. 

A final area where the shares of European and domestic works was looked at was the similar titles section 
when selecting a single title. Country level results show that Austria, Spain and France have the highest shares 
of European and EU27 works in this functionality. Of all countries, France has the highest share of domestic 
works displayed in its functionalities (30%) while Estonia and Hungary have the lowest (1%). Lastly, Spain has 
the highest share of UK works in its functionalities’ display.  

Amazon Prime has higher shares of European and domestic works in the functionality indicators and more 
broadly  throughout  the  service.  Broadly,  local  services  tend  to  have  fairly  high  shares  for  functionality 
indicators, which may be as a result of local services promoting  more  local productions as it may be  more 
difficult to secure rights to international films and shows. Voyo seems to have the highest European, EU27 and 
domestic works in its functionalities. Netflix has the highest share of UK works in its functionalities.  

The results by country and service are detailed in the below tables. 

277 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European works in audiovisual media services 

Table 69: Country-level functionality results 

AT 

BE 

CZ 

DK 

EE 

FR 

DE 

HU 

IT 

NL 

PL 

RO 

SK 

ES 

SE 

Total 

Number of local platforms  

1 

1 

0 

0 

1 

1 

1 

1 

1 

2 

2 

1 

0 

2 

2 

16 

Similar titles area 

100% 

25% 

100% 

75% 

100% 

25% 

20% 

100% 

100% 

50% 

100% 

100% 

100% 

75% 

50% 

75% 

Recommended section 

100% 

50% 

100% 

75% 

50% 

50% 

100% 

50% 

50% 

61% 

Autoplay function 

European works 

Similar titles section 

Similar titles section (different definition) 

Autoplay function 

Autoplay function (different definition) 

Recommended titles section 

Recommended titles section (different definition) 

Second similar titles section 

Second similar titles section (different definition) 

Similar titles section 

EU27 works 

Similar titles section (different definition) 

Autoplay function 

Autoplay function (different definition) 

Recommended titles section 

Recommended titles section (different definition) 

Second similar titles section 

Second similar titles section (different definition) 

Domestic works 

Similar titles section 

Autoplay function 

Recommended titles section 

Second similar titles section 

Similar titles section 

Autoplay function 

Recommended titles section 

Second similar titles section 

50% 

50% 

40% 

40% 
10% 

5% 
15% 

10% 
22% 

14% 
40% 

30% 
5% 

0% 
10% 

10% 
10% 

4% 
0% 

0% 

0% 

0% 

25% 

50% 

X 

X 

55% 

50% 
80% 

80% 
43% 

27% 

X 

X 

50% 

45% 
80% 

80% 
32% 

21% 

X 

35% 

80% 

10% 

75% 

50% 

0% 

0% 
10% 

0% 
23% 

15% 
32% 

23% 
0% 

0% 
10% 

0% 
10% 

5% 
18% 

18% 
0% 

0% 

0% 

9% 

25% 

20% 

10% 
40% 

40% 
55% 

49% 
58% 

43% 
20% 

10% 
30% 

30% 
50% 

44% 
50% 

37% 
0% 

0% 

19% 

21% 

25% 

25% 

75% 

50% 

X 

X 

X 

X 

30% 

55% 

10% 
0% 

0% 
37% 

20% 
50% 

0% 
38% 

27% 

14% 

X 

X 

X 

X 

10% 

40% 

5% 
0% 

0% 
21% 

0% 
39% 

0% 
26% 

13% 

9% 

X 

X 

40% 

40% 

60% 

0% 

X 

X 

45% 

45% 
57% 

29% 
47% 

0% 

X 

X 

30% 

25% 
41% 

24% 
40% 

25% 

X 

X 

10% 

10% 
37% 

37% 
45% 

39% 

X 

X 

X 

0% 

0% 
7% 

0% 
45% 

36% 

0% 

0% 

0% 

0% 

3% 

25% 

X 

21% 

5% 

30% 

X 

13% 

30% 

0% 

1% 

26% 

30% 

7% 

10% 

UK works 

0% 

10% 

X 

0% 

X 

X 

17% 

X 

10% 

5% 

9% 

5% 

5% 

5% 

0% 

12% 

15% 

5% 

30% 

25% 

X 

13% 

14% 

0% 

14% 

14% 

20% 

25% 

27% 

10% 

30% 

5% 

50% 

30% 

20% 
25% 

0% 
25% 

20% 
42% 

20% 
30% 

10% 
10% 

0% 
13% 

7% 
35% 

19% 
30% 

0% 

1% 

0% 

15% 

13% 

9% 

25% 

100% 

30% 

100% 

0% 
60% 

20% 
35% 

32% 
27% 

18% 
100% 

0% 
50% 

0% 
20% 

13% 
14% 

10% 
100% 

30% 
20% 

15% 
43% 

10% 
32% 

13% 
10% 

10% 
10% 

10% 
33% 

10% 
23% 

9% 
0% 

0% 

0% 

0% 

0% 

X 

X 

50% 

30% 
45% 

33% 
0% 

0% 

X 

X 

50% 

15% 
32% 

25% 
0% 

50% 

22% 

100% 

0% 

25% 

41% 

20% 

0% 
28% 

13% 
33% 

0% 
29% 

21% 
10% 

0% 
20% 

10% 
25% 

0% 
25% 

19% 
0% 

8% 

13% 

18% 

X 

X 

46% 

40% 
51% 

42% 
32% 

X 

X 
50% 

25% 
60% 

28% 
21% 

15% 

9% 

X 

X 

18% 

19% 
45% 

40% 
22% 

X 

X 
40% 

15% 
55% 

18% 
18% 

11% 

6% 

X 

X 

33% 

11% 

34% 

19% 

40% 

27% 

37% 

23% 

29% 

7% 

23% 

10% 

31% 

18% 

27% 

17% 
19% 

8% 

20% 

10% 

41% 

15% 

19% 

2% 

0% 

11% 

20% 

15% 

10% 

15% 

0% 

0% 

10% 

X 

X 

6% 

13% 

X 

15% 

15% 

0% 

14% 

10% 

13% 

18% 

20% 

14% 

6% 

15% 

11% 

7% 

14% 

10% 

13% 

278 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Table 70: Service-level functionality results (all local services aggregated) 

3 

Voyo  Disney+  Mubi  Prime  Netflix  Local 
16 
14 
56% 
86% 
50% 
64% 
13% 
86% 
20%  100% 

5 
67%  100% 
67% 
67% 
X 

10 
80% 
0%  100% 
40% 
0% 
30% 
X 

3 
100% 
100% 
67% 
X 

X 
75% 

65% 
90% 

83% 
64% 

64% 
X 

X 
70% 

60% 
87% 

80% 
58% 

57% 
X 
50% 
77% 
54% 
X 
5% 
7% 
2% 

X 
15% 

5% 
15% 

5% 
9% 

4% 
X 

X 
5% 

5% 
5% 

5% 
3% 

1% 
X 
0% 
5% 
0% 
X 
10% 
10% 
7% 

X 
X 

X 
X 

X 
44% 

28% 
X 

X 
X 

X 
X 

X 
33% 

22% 
X 
X 
X 
2% 
X 
X 
X 
12% 

18% 
44% 

33% 
30% 

16% 
33% 

20% 
22% 

15% 
33% 

23% 
18% 

12% 
24% 

15% 
8% 
20% 
8% 
15% 
12% 
16% 
14% 
12% 

5% 
30% 

80% 
70% 

25% 
17% 

70% 
74% 

16% 
34% 

66% 
53% 

19% 
32% 
10%  100% 

5% 
16% 

80% 
50% 

9% 
10% 

40% 
61% 

8% 
19% 

52% 
47% 

11% 

29% 
0%  100% 
30% 
2% 
37% 
3% 
24% 
2% 
0% 
10% 
10% 
19% 
16% 
8% 
12% 
19% 

Times appeared in analysis 
Similar titles area 
Recommended section 
Autoplay function 
Similar titles section 
Similar titles section  
(different definition) 
Autoplay function 
Autoplay function 
(different definition) 
Recommended titles section 
Recommended titles section  
(different definition) 
Second similar titles section 
Second similar titles section 
(different definition) 
Similar titles section 
Similar titles section  
(different definition) 
Autoplay function 
Autoplay function 
(different definition) 
Recommended titles section 
Recommended titles section  
(different definition) 
Second similar titles section 
Second similar titles section 
(different definition) 
Similar titles section 
Autoplay function 
Recommended titles section 
Second similar titles section 
Similar titles section 
Autoplay function 
Recommended titles section 
Second similar titles section 

European works 

EU27 works 

Domestic works 

UK works 

279 

 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Visibility of European and domestic works 

Information on the visibility of European and domestic works was also collected through mystery shopping. 
Shoppers were asked to write down the first ten titles on each section of the homepage, together with their 
label (i.e., French production, European production). This excluded the recommended or other similar sections.  

The assessment of these titles allowed for an analysis of the visibility of titles. At service level, Voyo (61%), 
Mubi (67%) and local services (65%) give the highest visibility of European works and overall, European works 
have the highest visibility on almost all services. As regards EU27 works, these enjoy the highest visibility on 
Mubi (59%), local services (55%) and Voyo (48%). Domestic works are mostly visible on local services (36%) 
and  Voyo  (33%).  Lastly,  UK  productions  have  lower  visibility  shares  on  all  of  the  most  frequently  tested 
services, with the highest shares being observed on Prime (16%) and Netflix (16%). Voyo is the highest for 
the secondary definitions at 56% and 46% for European and EU27 works. 

Table 71: Visibility of European and domestic work per service 

Voyo 

Disney 

Mubi 

Prime 

Netflix 

Local 

y
r
i
l
i

b
i
s
i
V

European 
EU27 
Domestic 
UK 
European 
(different definition) 
EU27 
(different definition) 

61% 
48% 
33% 
9% 

56% 

46% 

19% 
13% 
11% 
6% 

10% 

8% 

67% 
59% 
2% 
13% 

35% 

27% 

39% 
25% 
11% 
16% 

22% 

17% 

39% 
25% 
8% 
16% 

65% 
55% 
36% 
13% 

28% 

45% 

16% 

37% 

Country level results show that, on average, European works have the highest  visibility (49%),  followed by 
EU27 (38%). There are countries where European and EU27 works have very high visibility (with over 45%) 
and these are: Austria, Czechia, Spain and Sweden. Spain is the only country where domestic works has very 
high  visibility  (56%).  UK  productions  are  mostly  visible  in  Sweden  (21%)  and  Estonia  (19%).  With  the 
secondary definition we see Spain with 63% of European works being the highest. 

Table 72: Visibility of European works per country 

AT 

BE 

CZ 

DE 

DK 

EE 

ES 

FR 

HU 

IT 

NL 

PL 

RO 

SE 

SK 

Average 

European 

57% 

34% 

55% 

56% 

46% 

50% 

87% 

39% 

44% 

30% 

50% 

55% 

35% 

63% 

36% 

EU27 

51% 

26% 

46% 

43% 

32% 

35% 

69% 

29% 

34% 

21% 

37% 

43% 

25% 

50% 

25% 

Domestic 

21% 

7% 

16% 

29% 

7% 

4% 

56% 

22% 

1% 

12% 

30% 

28% 

16% 

17% 

4% 

UK 

6% 

12% 

12% 

16% 

18% 

19% 

11% 

11% 

15% 

12% 

13% 

14% 

9% 

21% 

11% 

49% 

38% 

18% 

13% 

European 
(different 
definition) 
EU27 
(different 
Definition) 

42% 

15% 

38% 

41% 

31% 

29% 

63% 

25% 

16% 

18% 

38% 

39% 

26% 

33% 

20% 

32% 

38% 

9% 

29% 

33% 

18% 

17% 

48% 

20% 

12% 

14% 

32% 

32% 

19% 

23% 

13% 

24% 

y
t
i
l
i

b
i
s
i
V

When looking at visibility as a prominence method used by SVoD services, using data from Ampere Analysis, 
we can use the popularity of the titles to analyse whether European works on the front page are more popular 
than non-European works. Specifically, the analysis done took the titles of the front page and divided them 
into European and non-European works. The average popularity scores of the European and non-European 
works were then calculated. These scores were then divided by the share of titles that were European or non-
European, respectively, thus providing a weighted popularity score. This procedure was done for each country. 
The results are shown below. 

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Table 73: Popularity scores by country 
European 
Country 
Popularity 

Non-
European 
Popularity 

Share of 
Non-
European 

Share of 
European 

Weighted 
Non-
European 
Popularity 

Weighted 
European 
Popularity 

AT 
BE 
CZ 
DE 
DK 
EE 
ES 
FR 
HU 
IT 
NL 
PL 
RO 
SE 
SK 

20.3719 
20.7925 
10.1548 
18.9594 
13.2053 
30.1099 
6.6520 
25.9795 
20.0399 
18.9959 
19.7165 
20.6202 
14.7837 
15.3630 
25.0134 

10.8690 
21.6428 
11.6934 
16.0974 
14.0501 
18.3342 
15.1739 
17.8673 
11.6553 
14.4181 
18.6204 
14.4770 
15.9431 
11.1734 
25.0619 

43.03% 
65.81% 
44.84% 
43.85% 
53.70% 
50.49% 
12.81% 
60.62% 
56.33% 
69.54% 
50.43% 
45.14% 
64.69% 
37.25% 
63.55% 

56.97% 
34.19% 
55.16% 
56.15% 
46.30% 
49.51% 
87.19% 
39.38% 
43.67% 
30.46% 
49.57% 
54.86% 
35.31% 
62.75% 
36.45% 

8.7659 
13.6831 
4.5536 
8.3145 
7.0911 
15.2015 
0.8524 
15.7487 
11.2879 
13.2098 
9.9431 
9.3087 
9.5632 
5.7227 
15.8972 

6.1922 
7.4001 
6.4498 
9.0380 
6.5054 
9.0778 
13.2295 
7.0362 
5.0902 
4.3917 
9.2301 
7.9416 
5.6300 
7.0113 
9.1339 

The analysis shows that of the European titles on the front page, the average popularity was the highest for 
Slovakia and the lowest for Austria. Broadly, the differences by country are not large except with Slovakian 
SVoDs promoting very popular European works. On the other hand, Spain has the lowest average popularity 
of non-European titles and Estonia the highest. Here again the differences between countries are not large 
except for the non-European titles on Spanish SVoDs being particularly unpopular. 

By looking at the weighted popularity scores, we can also compare the popularities between European and 
non-European  works  by  country.  Specifically,  we  see  that  Spain  is  the  standout  on  European  popularity 
compared  to  non-European  popularity.  In  France  and  Italy,  however,  non-European  titles  are  much  more 
popular  than  European  titles.  Generally,  it  would  seem  that  countries  with  smaller  domestic  film  industries 
would have less popular European titles, which we partly see with Estonia. Slovakia, on the other hand, has 
very popular European titles, which may be as a result of SVoDs being able to also promote popular Czech 
titles on their services. Larger EU Member States, however, should have larger domestic industries and thus 
more popular European titles, which we see with Spain, but not with France and Italy. The table shows that 
the greater popularity of non-European titles with Italy may be due to non-European titles being more present 
in the home page, whereas for France, it may be due to non-European titles being exceptionally popular. This 
may indicate that French SVoDs only promote the most popular non-European titles. 

When  aggregating  the  measures  of  prominence  in  the  availability,  advertising,  functionality,  and  visibility 
sections,  in  general,  services  in  France,  Germany,  and  Poland  tend  to  score  better  in  the  prominence 
measures whereas services in Estonia and Hungary tend to score worse. Again, these results tend to line up 
with the idea that larger countries with more developed film and TV industries are able to promote more local 
works whereas smaller countries rely on international productions. We see that, in general, Disney+, Amazon 
Prime and Voyo tend to score higher on the prominence measures compared to Netflix and Mubi.  

Qualitative inputs from the mystery shopping exercise 

There  are  also  some  qualitative  inputs  from  the  shoppers  that  are  important  to  include  to  provide  a  better 
understanding of what these results mean. In particular, these measurements of prominence are not the only 
way that a service may promote European works. For example, some shoppers noted the ability to search for 
titles based on language. Indeed, some services had different ways of promoting European works outside of 
the ones outlined through, for example, filters, labels, sorting, and tabs. For example, Netflix often allows the 

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ability to filter titles by language and Mubi provides a way of sorting by country and region outside of categories. 
In addition, services may not necessarily have a specific section for  European works but are still promoting 
European works. Specifically, one shopper noted of a local service (Canal+ in France) that despite there being 
no specific section for European works, nearly all titles in the catalogue were domestic and thus  European. 
Indeed, local services may have catalogues of only domestic works and thus see no need to explicitly provide 
a section for those works. 

5.4     Conclusions 

Building on the experience of the previous study monitoring the implementation of the AVMS Directive for DG 
CONNECT,  the  new  analysis  of  the  audiovisual  content  offer  has  relied  on  a  significantly  optimised 
methodological approach across all its components: 

-  For linear services, we increased the number of countries covered, while ensuring a better match of 
the channels monitored with the channels for which there was data available in the country reports. 
We also overhauled the data collection method, from a manual process to a cloud-based one, ensuring 
an improved rate of identification of the works mentioned in the electronic program guides. 

-  For non-linear services (VoD and SVoD), we optimised the coverage of countries and platforms in the 
secondary  data  analysed  while  carrying  out  a  bespoke  mystery  shopping  exercise  to  gauge  the 
prominence ensuring techniques employed by SVoD platforms, as experienced by subscribers. 

As  detailed  in  the  previous  sections,  in  line  with  these  methodological  improvements,  these  are  the  main 
findings: 

a.  Linear services  

According to the collected data and the analysys conducted,  the share of European works out of the total 
qualifying time is 38.4% across all Member States. Germany has the highest share of European productions 
broadcast (81.3%), showing also a significant increase from the previous monitored period (52.3% in 2020 – 
2021). The country with the lowest share of European works is Romania (17.2%), which shows a significant 
decrease from the previously monitored period (28.6% in 2020-2021).  

When  it  comes  to  quasi-independent  European  works,  our  data  shows  that  the  share  of  European 
independent productions is fairly low across all Member States assessed (less than 3%). Moreover, compared 
to 2020-2021, the share of European works shown at prime time is currently lower in all countries.  

For  Domestic  Works  the  highest  share  of  domestic  works  is  shown  in  Germany  (61.6%),  while  Estonia 
displays the lowest one (1.9%). On average, across all Member States, the share of Domestic Works amounts 
to 20%. 

As detailed in the dedicated section, the data captured in our study from the electronic program guides shows 
that there are significant differences between our results and the values for the same indicator reported by the 
Member States. There can be multiple causes for these differences but most likely they stem from differences 
in  the  methodology  used  to  identify  the  productions  and  quantify  their  share.  We  lack  the  technical  details 
regarding the methods employed by Member States to report the values for the indicators. This absence of 
information hinders our ability to compare and contrast the approaches uded by different entities.  

Nonetheless,  when  considering  various  characteristics  of  the  country-level  measures  implemented  by 
authorities with regards to the monitoring and reporting process, it appears that there is a correlation between 
these process characteristics and the size of the differences: the stricter the process, the better defined the 
reporting  and  monitoring  procedures,  the  lower  the  differences  between  the  values  we  found  and  those 
reported by Member States.   

b.  Non-linear services 

The content analysis for VoD services covered two distinct but related issues: catalogue composition and the 
methods used to ensure prominence of European works. For the analysis of the content, we relied on data 
provided by Just watch covering in total 1 722 VoD services across 39 targeted countries. For the analysis of 
prominence, we relied on a novel mystery shopping exercise, through which we analysed the content offered 
by four SVoDs for 15 EU Member States (except for Germany where 5 SVoDs were included) to understand 
to what extent SVoD services ensure visibility of European and EU27 works. 

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When it comes to the content of the  catalogues, according to the collected data, 38% of the content of the 
catalogues analysed across all the VoD services and 35% of the sample of 21 EU Member States and Norway 
covered  by  this  study  are  European  works.  Overall,  this  represents  an  increase  of  2  percentage  points 
compared to the 2020-2021 data.  Despite the small overall increase, there are significant differences across 
countries for 2023 data, between the 2021 and 2023 data in the case of the same VoD provider, and between 
providers across both 2021 and 2023 data.  

When it comes to co-productions, the US was systematically the leading country of (co-)production for both 
the current period covered by the study and the previous one. When it comes to EU Member States that appear 
to be significant co-producer countries, the top countries are France, Germany and Italy, the share of each MS 
as a country of co-production varying from one market to the other. To some extent, this also explains our 
findings when it comes to domestic and non-domestic works: France, Germany and Italy have the highest 
shares of domestic works present in the catalogues offered by VoD providers in these markets.  

When  it  comes  to  the  prominence  of  European  works,  the  results  show  that  40%  of  services  include 
dedicated sections on the home page of the SVoD providers for European works and works from the targeted 
country. Moreover, 48% of the services analysed do offer the option to filter the works present in their catalogue 
by country or region. 

In terms of the offer, the catalogues analysed show that EU27 works are widely available while the availability 
of domestic works differs significantly across markets and providers. 

When it comes to advertising practises, the majority of ad banners experienced by our mystery shoppers were 
for European works.  

Considering these findings, the differences between the data reported by Member States and our estimates 
for the indicators of interest, there are several recommendations that in our view could be considered for the 
future: 

-  As  a  recommendation  for  carrying  out  a  similar  study,  from  a  methodological  perspective,  there  is 
room  to  improve  the  design  of  the  process  through  which  we  identify  and  append  the  required 
additional information for the classification of the works appearing in the Electronic Program Guides. 
New tools such as Large Language Models (e.g., ChatGPT) could be utilised to increase the efficiency 
of  the  process  and  the  accuracy  of  classification  of  the  works  into  the  categories  relevant  for  the 
indicators. 

-  As a recommendation for Member States’ reports, adapting and implementing what can be considered 
good practices in the way in which national authorities and broadcasters verify, monitor and report the 
indicators could also lead to significant improvements,.  

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Annex 1: Country fiches (Volume 1) 

The National Country Fiches for all EU Member States and EEA countries can be found in an annex attached 
to this report (Annex 1). 

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Annex 2: Member States data reporting 
(Volume 1) 

The monitoring data reported by Member States can be found in an annex attached to this report (Annex 2).  

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Annex 3: Mystery shopping observation grid 
(Volume 3) 

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1. Date and time2. SVoD service3. Data collectorLangauge chosen for the analysis:Persona being used (Persona 1 or Persona 2):Name of data collector:Targeted country:Country of company (service) headquarters:In what other languages can the service be accessed in the targeted country?End time:Name of the SVoD service analysed:Link to the SVoD service:Start date:Start time:End date:Introduction section:Select the SVoD (Service-on-demand)service. Familiarise yourself with the webpage of the service. For each service, record a separate observationPlease note:The overall objective of this exercise is to gain insight into the extent to which SVoD services use any prominence measures with the aim of promoting European works.A European work is defined as any work that has at least one production company (or producer) originating in EU Member States or from European third States party to the European Convention on Transfrontier Television of the Council of Europe. You will be given a full list of the EU Member States and those that are part of the Convention on Transfrontier Television. The purpose of the first section (Visibility) is to understand the extent to which European works are present on the homepageof the services. Importantly, the first part of this section must be conducted before interacting with the service in any way. This ensures that the screenshots of the homepage contain the titles that users can find on the homepage without the intervention of the Artificial Intelligence/Machine learning algorithms. The purpose of the next two sections (Advertising, Availability) is to understand if, at first sight, there are any obvious sections or areas on the service where European works   are promoted/ made available. The purpose of the third section (Functionality) is to gain insight into what users receive as recommendations or similar content based on their interaction with the service. 
 
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Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.Etc.(INSERT NAME OF TITLE 2 + label in parantheses)(INSERT NAME OF TITLE 2 + label in parantheses)(INSERT NAME OF TITLE 2 + label in parantheses)(INSERT NAME OF TITLE 2 + label in parantheses)(INSERT NAME OF TITLE 2 + label in parantheses)(INSERT NAME OF TITLE 2 + label in parantheses)(INSERT NAME OF TITLE 1 + label in parantheses)(INSERT NAME OF TITLE 1 + label in parantheses)(INSERT NAME OF TITLE 1 + label in parantheses)(INSERT NAME OF TITLE 1 + label in parantheses)(INSERT NAME OF TITLE 1 + label in parantheses)(INSERT NAME OF TITLE 1 + label in parantheses)(INSERT NAME OF SECTION 1 from HOMEPAGE)(INSERT NAME OF SECTION 2 from HOMEPAGE)(INSERT NAME OF SECTION 3 from HOMEPAGE)(INSERT NAME OF SECTION 4 from HOMEPAGE)(INSERT NAME OF SECTION 5 from HOMEPAGE)ETC.Visibilitysection:Please note: Most Video-on-demand services have multiple sections on the home page which present/feature a group of titles according to a specific common feature/logic. You may find a separate grouping of ‘new releases’; or ‘trending/popular’ or ‘recommended’, ‘Top 100 TV shows in country X’ titles etc, or titles grouped according to a separate theme (‘TV War & Politics’,‘Exciting thrillers’ ‘Titles for the family’ etc) etc). Often (though not necessarily) these are presented in a row and have a ‘scrolling to the right’ function which allows the user to find additional titles from that section. For this part, please provide screenshots of the front page (home page) of the VoD service which capture 10 titles per section. This will guide your ability to answer the questions in this section. Q1. If the titles have labels specifying if a work is European or not (or from a targeted country or not), please write down the first 10 titles listed on each section of the homepage, together with their label. Please exclude the recommended and similar sections.If the titles DO NOT have labels specifying if a work is European or not, please only write down the names of the first 10 titles listed on the first 10+ sections of the homepage. Again, please exclude the recommended and similar sections.For this question, please use the below table. Please write the names of the titles and add the label (European/non-European/ from targeted country) in parantheses if applicable: 
 
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(Insert Name of Title 1)(Insert Name of Title 2)(Insert Name of Title 3)(Insert Name of Title 4)(Insert Name of Title 5)Advertisingsection:Q2. Please check if there is a banner/ poster/ ad promoting a work on the front page (home page). Please indicate the countries of origin of the title(s) by searching the IMDB database or any other reliable source. Please also indicate the number of banners/posters/ads that you could find. Please note: the countries given are EU27 countries and those that are part of the Convention on Transfrontier Television. Thus, if a title is a co-production and was produced by, for example, Belgium, Austria and the US, you would place an ‘X’ in the table for Belgium, Austria and indicate the number of other non-European countries (in the given example, there is 1 non-European country).Please fill in the following tables:TABLE 1: Place an X where applicableIf your answer was "1" in the above table (TABLE 1), please also fill in the following table:**In the below tables, you analyse the titles that you get by searching "European". Again, please use the IMDB database to identify the origins of the countries or production (or any other reliable source).(Insert Name of Title 6)(Insert Name of Title 7)(Insert Name of Title 8)(Insert Name of Title 9)(Insert Name of Title 10)2. No, there was not a way to search for European content3. Yes, there was a way to search for titles from the targeted country4. No, there was not a way to search to titles from the targeted country(Insert Name of Title 1)(Insert Name of Title 2)(Insert Name of Title 3)(Insert Name of Title 4)(Insert Name of Title 5)Title 6:etc.1. Yes, there was a way to search for European contentTitle 3:Title 4:Title 5:Clarify how it/they was/were presentedTitle 1:Title 2:EuropeanYes/ NoTargeted countryYes/ NoAvailabilitysection:Q3. Was there a dedicated section/ area/ row on the homepage that was titled/ included only European works or works from the targeted country?Q3.1. Please write down all the names of the titles that you could find on this dedicated section/ area/ row on the homepage that was titled/ included only European works.Q4. Was there a way to search for European content/ titles or for content/ titles from the targeted country? Test the search bar by typing the name of the targeted country or "European". After searching these search terms, test the first 10 titles for each by identifying the origins of the countries of production. Please note:It is important that you test these search terms both in English and in the language of the survey.If your answer was "3" in the above table (TABLE 1), please also fill in the following table:**In the table below you analyse the titles that you get when typing the name of the targeted country. Again, please use the IMDB database to identify the origins of the countries or production (or any other reliable source).(Insert Name of Title 6)(Insert Name of Title 7)(Insert Name of Title 8)(Insert Name of Title 9)(Insert Name of Title 10)(Insert Name of Title 1)(Insert Name of Title 2)(Insert Name of Title 3)(Insert Name of Title 4)(Insert Name of Title 5) 
 
 
 
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Place an X where applicable (for answer option 3, please also indicate which categories)EuropeanYes/NoTargeted countryYes/NoClarify how it/they was/were presented1. No category based on the country or region of origin2. Only general category including all non-US or non-English speaking titles (e.g., 'international', 'world' etc.)3. Separate categories offered for specific countries/ regions (indicate which too)4. Other (please explain)Q5. When you open the menu, does it offer pre-set categories of content based on origin of titles? Please indicate:Q6. Was there another alternative way to find European content or works from the targeted country outside of questions 3 and 4? (Insert Name of Title 5)(Insert Name of Title 6)(Insert Name of Title 7)(Insert Name of Title 8)(Insert Name of Title 9)(Insert Name of Title 10)(Insert Name of Title 1)(Insert Name of Title 2)(Insert Name of Title 3)(Insert Name of Title 4)Functionalitysection:Q7. Select 10 titles at random or add them in your watchlist. Is there a section on the home page suggesting 'similar' content. If so, please indicate the countries of origin of these titles. Test all titles, or if more than 10 titles, test only 10 titles. Please use the IMDB database for this question too (or any other reliable source). If there is no 'similar' section and only a 'recommended' section, ignore this question.Please note: the 'similar' section can appear on the homepage under various forms. For example, on Netflix, there are multiple 'similar' sections based on previous titles that were watched. Specifically, the 'similar' section appears under the name of "Because you watched title X". Thus, please carefully analyse the homepage to identify the 'similar' section(s). Please then indicate theexact way the 'similar' section was named on the platform in the table below (last row).As exaplained above too, the countries given in the table are EU27 countries and those that are part of the Convention on Transfrontier Television. Thus, if a title is a co-production and was produced by, for example, Belgium, Austria and the US, youwould place an "X" in the table for Belgium, Austria and also indicate the number of other non-European countries (in this case, 1). If there was no 'similar' section on the homepage, please indicate this in the table.(Insert Name of Title 8)(Insert Name of Title 9)(Insert Name of Title 10)(Insert Name of Title 1)(Insert Name of Title 2)(Insert Name of Title 3)(Insert Name of Title 4)(Insert Name of Title 5)(Insert Name of Title 6)(Insert Name of Title 7)Q8. Was there an autoplay function after finishing a title? If so, please indicate the countries of origin of these titles by using the IMDB database (or any other reliable source). Test the 10 titles on the home page. If there was no 'autoplay' function, please indicate this in the table. 
 
 
 
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(Insert Name of Title 6)(Insert Name of Title 7)(Insert Name of Title 8)(Insert Name of Title 9)(Insert Name of Title 10)Title 6:etc.(Insert Name of Title 1)(Insert Name of Title 2)(Insert Name of Title 3)(Insert Name of Title 4)(Insert Name of Title 5)Title 3:Title 4:Title 5:Title 1:Title 2:Q9. As part of the description of the title or anywhere else (for example, when you hover over the titles), does it suggest any other titles as 'similar'. If so, select all or if more than 10, the first 10 suggested titles of the first 5 titles on the home page and write down their names.Q10. If there was a recommended section on the home page, please list the first 10 titles showed there. Then, please indicate the countries of origin of these titles by using the IMDB databse or any other reliable source.If there was no 'recommended' section on the homepage, please indicate this in the table. 
 
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Annex 4: Linear services channel list 
(Volume 3) 

Member State  

AT  

Channels covered 

ORF1  ORF2  ORF3  ATV  ATV 2 HD  Puls4  ZDF  Arte  Kinderkanal  RTL  RTL2  Pro 
Sieben  Sat.1  Vox  Kabel 1  Super RTL  Sixx  Dmax  RTL Plus (RTLUp)  ProSieben 
Maxx  Sat.1 Gold  Comedy Central  Kabel 1 Doku  Schau TV  3sat HD  Servus TV  
Krone TV  Puls24 HD  FashionTV  NTV  RTL NITRO  HD  Servus TV HD  Kika  

Prima (Prima Family)  Primacool  Primalove  Primazoom  Nova  Fanda (Nova Action)  
Nova  Gold  (Telka)    Ocko    HBO  Comedy    Cinemax    Natura    Film  Europe    Kino  Cs  
Nickelodeon  Prima MAX HD  Prima Krimi  HBO (ČR  SR)  Cinemax 2  AMC HD  Nova 
Cinema  Nova 2 (SMICHOV)  Horor Film (CS Horror)  Kinosvet (CS Mystery)  CT 1  
CT2  CT art  Prima Comedy Central  Kino Barrandov  Seznamcz TV  HBO 2 (ČR  SR  
Maďarsko  Rumunsko  Moldavia)  WAR svět válek (CS History)  MTV  Noe TV  JOJ 
Cinema  MTV Hits  Spektrum  Pohoda  Barrandov TV  Spektrum HOME  Ocko Express 
Rebel  JoJ Family  TV Paprika  Hobby TV  Nick Jr  Ocko Blackhd  Ocko Gold (STAR)  
Barrandov Krimi (Barrandov PLUS)  Mnam TV  Lounge TV  VH1  Mnau TV  CS Film  
Film+  FILMpro  Minimax  OIK TV  Šlágr TV  

TF1  France 2  France 3  France 5  M6  M6 Music  Mangas  C8  W9  TMC  TFX    France 
4  CSTAR  Gulli  L Equipe  6ter   RMC Story  RMC Decouverte  TV5MONDE  RTL 9  
Canal+ Cinema  Canal+ Series  OCS Max  OCS Choc  OCS Geants   Action   AB  1  
Comedie+  serieclub  TIJI  Piwi+  TeleToon+   Animaux  Toute l'histoire  Histoire TV  
Ushuaia  TV    Planete+    Platene+  Crime  Investigation    J-One    Trace  Urban    Mezzo  
Seasons  Disney Channel Wallonia  CANAL +  NRJ12  Cine+ Classic  Teva  Melody 
TV  Cine+ Famiz  Chasse  et Peche  Paris Premiere   Cine+ Club  TF1 Series-Films  
Cine+  Frisson    Cherie  25    Cine+  Emotion    Cine+  Premier    OCS  City    PLANETE+ 
Aventure Experience  MUSEUM  Clique TV  RFM TV  J  Equidia Live  Game One  MCM  
Polar+  TV Breizh  ARTE  BFM 

KiKa  ARD1 (Das Erste)  ARD ONE  ZDF  RTL  SAT.1  VOX  SAT.1 Gold  NITRO (RTL 
Nitro)  DMAX  TELE 5  ProSieben MAXX  sixx  TLC  Super RTL  Disney Channel  ARD-
alpha    ARTE    Bayerisches  Fernsehen    hr-Fernsehen    Kabel  Eins  Doku    MDR 
Fernsehen (Mitteldeutscher Rundfunk)  NDR Fernsehen  Phoenix  RTLUp (RTL PLUS)  
Servus TV Deutschland  SWR Fernsehen  ZDF info  ProSieben  3Sat  Kabel 1  RBB 
Fernsehen    RTL  zwei    zdf  neo    Radio  Bremen  TV    SR  Fernsehen    BR  Fernsehen  
Comedy Central (Germany)  n-tv    

RTL Klub  TV2  VIASAT3  DUNA Televizio  Duna World  M5  M1  M4  ATV  Hir TV  
Cool  Comedy Central  TV4  STORY4  TV6/ VIASAT6  FEM3  FIX HD  PAX TV  D1 TV  
RTL II  Super TV2  Hatoscsatorna  Galaxy4  M2/Petofi TV  ATV Spirit  Film+  Filmcafe  
Mozi+  AXN  AMC  Sorozat+  RTL+  Film4  Paramount Channel  Discovery Channel  
National Geographic  Travel Channel  TLC  HISTORY  Nickelodeon  Cartoon Network  

CZ  

FR  

DE  

HU  

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works in audiovisual media services 

Slager  TV    Balaton  Televizio    Apostol  TV    Érd  Televízió    Főnix  Független  Városi 
Televízió  Irány Televízió Miskolc  Minimax  Film Mania  DEKO TV/ Spektrum Home  
Disney Channel  RTL GOLD  Spektrum  TV Paprika  National Geographic Wild  DikhTV  
9.TV  Gotthard TV   Gyöngyösi TV’  Kecskeméti TV  Szeged TV  

Sky Uno  Sky Atlantic  Sky Arte  TV8  Comedy Central  MTV  Cielo  La 5  Real Time  
TOP crime  DMAX  Sky Cinema Due  Sky Cinema Family  Sky Cinema Action  Sky 
Cinema Suspense  Sky Cinema Romance  Sky Cinema Drama  Sky Cinema Comedy  
Sky Cinema Uno  Sky Cinema Uno +24  Iris  Focus  Food Network  Sky TG24  DeAKids  
DeAKids +1  Nick Jr  Nickelodeon  DeAJunior  Super!  La7  La7d  Rai 4  Rai Movie 
(Raisat)   DEEJAY TV/ NOVE   K2  -Frisbee-   RTL  102.5   Rete  4   Canale  5   Italia  1  
TV2000  Cartoonito  Boing  Rai1  Rai2  Rai3  Rai5  Rai Premium (Raisat)  Rai Gulp  
Rai Yoyo (Raisat)  Sky Meteo24  Rai Storia  National Geographic  NAT GEO WILD  
MEDIASET EXTRA  TGCOM24  VH1  Giallo  Italia 2  Nat Geo Wild +1.  

FOX    Discovery    NPO  1  extra    NPO  2  extra    RTL  Crime    Nickelodeon  NL    Disney 
Channel  (Dutch  NL)    Disney  XD    Comedy  Central  (ex.  The  Box)    BBC  First  
Investigation Discovery  NPO 1  NPO 3  SBS 9  National Geographic NL  MTV NL  RTL 
5  24 Kitchen  NPO 2  SBS 6  Net5  HISTORY Channel  TV Gelderland  RTL 4  RTL 7  
RTL 8  BVN  L1  Nick Junior  Veronica (ex V8/FOX8)  The Learning Channel  RTV Oost  
RTV Utrecht  

TVP 1  POLSAT  TVN 7  TV 4  TV 6  TV Puls  PULS 2  POLSAT 2  TVP Historia  TVN 
Style  TVP Seriale  TVN Fabula  AXN Polska  ZOOM TV  Fokus TV  TLC  National 
Geographic  Comedy Central  MiniMini+  Eska TV (ex. 8.TV)  HGTV (ex. TVN METEO 
ACTIVE)  POLSAT Café  TVN Turbo  POLSAT Play  TVP ABC  13 Ulica  CANAL+ 4K  
Cartoon Network/ TNT  TV Trwam  Discovery  Disney Junior  TVP Kultura  HISTORY  
TVS  TVN  Nickelodeon Polska  TVP HD  POLSAT Film  FOX  Nick Jr  Polo TV  TVP 
2  TVP Rozrywka  Nowa TV  WP  METRO  Super Polsat  Eska TV Extra  TTV  Kino 
Polska  TVN 24 Biznes i Swiat (TVN24 BiS)  Stopklatka  TVP Polonia   

PRO GOLD (Acasa GOLD)  Acasa TV (PRO 2)   Credo TV   Alfa Omega TV   Prima 
Sport  1  (Look  Plus)    Cartoon  Network    Boomerang    Disney  Junior    Disney  Channel  
Nickelodeon  Minimax  Comedy Central  AXN  PRO Cinema  History Channel  TVR 1  
PRO TV  Antena 1  National TV  Happy Channel  Film Cafe  Kanal D  Antena Stars  
Digi Animal World  Digi Life  Digi World  Diva  Film Now (DIGI FILM)  Orizont TV  Prima 
TV  PRO TV International  TV1000  TVR 2  TVR International  TLC  Antena International  
VTV  Erdely TV  Etno TV  Medika TV  Bucuresti TV  Mooz Hits  Mooz Ro  Mooz Dance  
Agro TV  A7 TV  Cinemaraton  Cinethronix  Digi 4K  Favorit TV  National 24 Plus    U 
TV   

LA 1  A Punt  Canal Extremadura  TVG - TV Galicia  Andalucia TV  ETB 2  La Otra  
Fox  TNT  Calle 13  Neox  Atreseries  Energy  Trece (13 TV)  Ten  National Geographic  
DKISS    Disney  Channel    Boing    ETB  3    TVG  Europa    Comedy  Central    DMAX 
(Discovery MAX)  Paramount Network  33  TPA 8  La 2  Antena 3  Cuatro  LaSexta  
FDF  Clan TV  ETB 1  TV3  La 7 TV  Telemadrid  Somos  Caza y Pesca (Spanish)  
Canal 24 horas  8TV  Aragon Television  Be Mad Tv  Canal Sur Television  CMT/CMM  
Divinity (Spain)  ETB4  IB3  Mega TV (Spain)  Antena Nova  Super 3/33  Telecinco  
TPA 7  TV Canaria  Antena Neox  #0  AMC  AXN  AXN White  SYFY   

IT  

NL  

PL  

RO  

ES  

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works in audiovisual media services 

TV3  TV4  TV6  Sjuan  TV8  Kanal 9  TV10  Kanal 11 (TV 11)  TV12  Discovery Channel  
Kunskapskanalen  SVT24  TV4 Fakta  TLC  BBC Brit  TV4 Film  TV4 Guld  Nick Jr.  
Nickelodeon    Investigation  Discovery    Kanal  10    Animal  Planet    Animal  Planet  HD  
National Geographic  History Channel  Kanal 5  SVT Barnkanalen  SVT1  SVT2  FOX  
TV4 HD  TV Finland  SF-Kanalen/ C More Golf  

AB3 (FR-BE)  AB Xplore (AB4) (FR-BE)  BE 1 (FR-BE)  BE Cine (FR-BE)  BE Series 
(FR-BE)    La  Deux  (RTBF2)  (FR-BE)    La  Trois  (RTBF3/  OUFTIVI)  (FR-BE)    La  Une 
(RTBF1) (FR-BE)  RTBF (Services : La Une  La Deux  La Trois) (FR-BE)  Dobbit TV 
(FR-BE)  Canal Z (FR-BE)  RTL TVi (FR-BE)  TF 1 (FR-BE)  France 2 (FR-BE)  France 
3 (FR-BE)  Club RTL (FR-BE)  Plug RTL (FR-BE)  TV Breizh (FR-BE)  Nickelodeon FR 
(FR-BE)  ARTE (FR-BE)  France 5 (FR-BE)  Disney Channel (FR-BE)  MTV (FR-BE)  
Disney  Junior  (FR-BE)    France  4  (FR-BE)    Cartoon  Network  (FR-BE)    13EME  RUE 
(FR-BE)    

Een (VRT) (NL-BE)  Canvas (NL-BE)  Ketnet (Op Twaalf/ Op 12) (NL-BE)  VTM (NL-
BE)    Qmusic  (NL-BE)    Q2  (2BE)  (NL-BE)    VTM  Kids  (VTMKZoom)  (NL-BE)    Vitaya 
(VTM3) (NL-BE)  Kanaal Z (NL-BE)  Vier (VT4) (NL-BE)  Vijf (NL-BE)  ZES (NL-BE)  
VlaamsParlement TV (NL-BE)  Stories TV (NL-BE)  CAZ (ACHT) (NL-BE)  Studio100 
TV (NL-BE)  MENTtv (NL-BE)  Njam! (NL-BE)  Dobbit (NL-BE)  Plattelands TV (NL-BE)  
Play More Cinema (NL-BE)  Play More Kicks (NL-BE)  Play more Black (NL-BE)  Eclips 
TV (NL-BE)  ATV (NL-BE)  AVS (NL-BE)  ROB-TV (NL-BE)  WTV-Zuid (NL-BE)  Focus 
(NL-BE)  RTV (NL-BE)  TVL (NL-BE)  TV-Oost (NL-BE)  Ring TV (NL-BE)  NPO 1 (Ned 
1) (NL-BE)  Nickelodeon (NL-BE)  MTV (NL-BE)  Discovery Channel (NL-BE)  National 
Geographic  (NL-BE)    Nick  JR  (NL-BE)    FOX  (NL-BE)    RTL  TVi  (NL-BE)    Comedy 
Central (NL-BE)  TLC (NL-BE)  

DK4  DR1  DR2  DR Ramasjang  TV 2 (Denmark)  TV 2 Charlie  TV 2 Fri  TV 2 Zulu  
6’eren  TV 3 Danmark  Kanal 5 Danmark  TV3+  Disney Channel  TV3 Puls  Discovery 
Channel Denmark  Canal 9  TLC  Nickelodeon Denmark  National Geographic Denmark  
Investigation Discovery  Animal Planet Europe  

DK4  DR1  DR1Syn  DR2  DR2Syn  (DR P3) DR3  DR Ramasjang  TV 2 (Denmark)   TV 
2 Bornholm  TV 2 Charlie   TV 2 Fri  TV 2 FYN  TV 2 Lorry  TV 2 NORD  TV 2 Play 1  
TV 2 Play 3  TV 2 Zulu   TV 2 ØSTJYLLAND  TV Midtvest  TV SYD  TV ØST (Denmark)  
6’eren  TV 3 Danmark  Kanal 5 Danmark  TV3+  Disney Channel  TV3 Puls  Discovery 
Channel Denmark  Canal 9  TLC  Nickelodeon Denmark  National Geographic Denmark  
Investigation Discovery  Disney Junior 

DK4  DR1  DR2  (DR P3)  TV 2 (Denmark)   TV 2 Bornholm  TV 2 Charlie   TV 2 Fri  
TV 2 FYN  TV 2 Lorry  TV 2 NORD  TV 2 Play 4  TV 2 Zulu   TV 2 ØSTJYLLAND  TV 
Midtvest  TV SYD  TV ØST (Denmark)  6’eren  TV 3 Danmark  Kanal 5 Danmark  TV3+  
Disney Channel  TV3 Puls  Discovery Channel Denmark  Canal 9  TLC  Nickelodeon 
Denmark    National  Geographic  Denmark    Investigation  Discovery    Disney  Junior  
Animal Planet Europe  

Dajto TV  Duck TV  Dvojka (STV 2)  Jednotka (STV 1)  Joj Plus (PLUS)  Joj TV  Life 
TV  Markiza  RiK  TA3  TV DOMA  TV Lux  TV WAU  ŤUKI  Nova International  Prima 
Plus  Minimax  

EESTI KANAL    ETV  ETV+  Filmzone  Filmzone+  Duo 4 (Kanal 11)  Duo 5 (Kanal 
12)  Kanal 2  Orsent TV  TV3  TV6  TVN  SEITSE/MyHits  Alo TV  Kidzone TV  Kidzone 
Mini (Kidzone Plus)  Smartzone  3+ Estonia  Fox  Fox Life  SET  National Geographic  
Sonny Turbo  Discovery Channel  TLC 

SE  

BE-FR  

BE-NL  

DK (tvguide)  

DK (tv.yousee)  

DK (tvtid.tv2)   

SK  

EE  

294 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Annex 5: Non-linear services channel list 
(Volume 3) 

Country  Services covered 

Country  Services covered 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  Blockbuster  BritBox  BroadwayHD  
C More  Classix  Crunchyroll  Cultpix  Curiosity Stream  Dansk Filmskat  Dekkoo  Discovery Plus  
Disney Plus  DocAlliance Films  DOCSVILLE  DRTV  Eventive  FilmBox+  Filmstriben  Filmzie  
Google Play Movies  GuideDoc  Hayu  HBO  HBO Max  HBO Max Free  Hoichoi  Lionsgate Plus  
Magellan TV  Microsoft Store  MUBI  Netflix  Netflix Kids  Pluto TV  Rakuten TV  SF Anytime  
SkyShowtime  Spamflix  Sun Nxt  Takflix  True Story  TV 2  Viaplay  WAKANIM  WOW Presents 
Plus   YouTube  Premium    GuideDoc   Hayu   HistoryPlay  Amazon Channel  Hoichoi   Home  of 
Horror  Home of Horror Amazon Channel  Joyn  Joyn Plus  Kino on Demand  Kividoo  LaCinetek  
Lionsgate Plus  Love and Passion Amazon Channel  Magellan TV  MagentaTV  maxdome Store  
MGM Amazon Channel  Microsoft Store  Moviedome Plus Amazon Channel  MovieSaints  MTV 
Plus Amazon Channel  MUBI  MUBI Amazon Channel  Netflix  Netflix basic with Ads  Netflix Kids  
Netzkino  NRK TV  Pantaflix  Paramount Plus  Paramount+ Amazon Channel  Plex  Pluto TV  
Popcorntimes    Rakuten  TV    Rakuten  Viki    realeyz    Realeyz  Amazon  Channel    RTL  Passion 
Amazon Channel  RTL+  Shudder  Shudder Amazon Channel  Silverline Amazon Channel  Sky 
Go  Sky Store  Sony AXN Amazon Channel  Sooner  South Park  Spamflix  Starz Play Amazon 
  Studiocanal  Presents 
Channel 
MOVIECULT Amazon Channel  Sun Nxt  Superfresh Amazon Channel  Takflix  True Story  Turk 
On  Video  Amazon  Channel    Universcine    Videobuster    WAKANIM    wedotv    WOW    WOW 
Presents Plus  Yorck on Demand  YouTube  YouTube Premium  ZDF  ZDF Herzkino Amazon 
Channel 

  Studiocanal  Presents  ALLSTARS  Amazon  Channel 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  Be TV Go  BroadwayHD  CineMember  
Classix    Crunchyroll    Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films  
DOCSVILLE    Eventive    FilmBox+    Filmzie    Google  Play  Movies    Hayu    Hoichoi    LaCinetek  
Magellan TV  meJane  Microsoft Store  MUBI  Netflix  Rakuten TV  RTBF  RTL Play  Sooner  
Spamflix  Sun Nxt  Takflix  True Story  VRT MAX  WOW Presents Plus  Yelo Play  YouTube  
YouTube Premium 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+    Filmzie    GuideDoc    HBO  Max    Hoichoi    Magellan  TV    MUBI    Netflix    Nova  Play  
SkyShowtime  Spamflix  Sun Nxt  Takflix  True Story  WOW Presents Plus  Zee5 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+  Filmzie  Google Play Movies  HBO Max  Hoichoi  Magellan TV  MUBI  Netflix  O2 TV  
Spamflix  Sun Nxt  Takflix  True Story  Voyo  WOW Presents Plus 

AT 

BE 

BG 

CZ 

295 

 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

DE 

DK 

EE 

EL 

ES 

Alleskino  Amazon Arthaus Channel  Amazon Prime Video  Amazon Video  Animax Plus Amazon 
Channel  Aniverse Amazon Channel  Apple iTunes  Apple TV Plus  Argo  Arte  Arthouse CNMA 
Amazon Channel  ArthouseCNMA  AVA HBZ  AVA VOBB  BBC Player Amazon Channel  Behind 
the Tree  Bloody Movies Amazon Channel  blutv  BluTV Amazon Channel  BroadwayHD  Chili  
Cinema of Hearts Amazon Channel  Classix  Comedy Central Plus Amazon Channel  CONtv  
Crunchyroll    Cultpix    Curiosity  Stream    Das  Erste  Mediathek    Dekkoo    Discovery  Amazon 
Channel    Discovery  Plus    Discovery  Plus  Amazon  Channel    Disney  Plus    DocAlliance  Films  
DOCSVILLE  Dogwoof On Demand  Eventive  Film Total Amazon Channel  FilmBox+  filmfriend  
filmingo  Filmlegenden Amazon Channel  Filmtastic  Filmtastic Amazon Channel  Filmzie  Flimmit  
Freevee    Google  Play  Movies    GRJNGO  Amazon  Channel    GuideDoc    Hayu    HistoryPlay 
Amazon Channel  Hoichoi  Home of Horror  Home of Horror Amazon Channel  Joyn  Joyn Plus  
Kino  on  Demand    Kividoo    LaCinetek    Lionsgate  Plus    Love  and  Passion  Amazon  Channel  
Magellan TV  MagentaTV  maxdome Store  MGM Amazon Channel  Microsoft Store  Moviedome 
Plus Amazon Channel  MovieSaints  MTV Plus Amazon Channel  MUBI  MUBI Amazon Channel  
Netflix    Netflix  basic  with  Ads    Netflix  Kids    Netzkino    NRK  TV    Pantaflix    Paramount  Plus  
Paramount+ Amazon Channel  Plex  Pluto TV  Popcorntimes  Rakuten TV  Rakuten Viki  realeyz  
Realeyz Amazon Channel  RTL Passion Amazon Channel  RTL+  Shudder  Shudder Amazon 
Channel  Silverline Amazon Channel  Sky Go  Sky Store  Sony AXN Amazon Channel  Sooner  
South Park  Spamflix  Starz Play Amazon Channel  Studiocanal Presents ALLSTARS Amazon 
Channel  Studiocanal Presents MOVIECULT Amazon Channel  Sun Nxt  Superfresh Amazon 
Channel    Takflix    True  Story    Turk  On  Video  Amazon  Channel    Universcine    Videobuster  
WAKANIM    wedotv    WOW    WOW  Presents  Plus    Yorck  on  Demand    YouTube    YouTube 
Premium  ZDF  ZDF Herzkino Amazon Channel 

Acorn  TV    Amazon  Prime  Video    Apple  iTunes    Apple  TV  Plus    Argo    Blockbuster    BritBox  
BroadwayHD  C More  Classix  Crunchyroll  Cultpix  Curiosity Stream  Dansk Filmskat  Dekkoo  
Discovery  Plus    Disney  Plus    DocAlliance  Films    DOCSVILLE    DRTV    Eventive    FilmBox+  
Filmstriben  Filmzie  Google Play Movies  GuideDoc  Hayu  HBO  HBO Max  HBO Max Free  
Hoichoi   Lionsgate  Plus   Magellan TV   Microsoft Store   MUBI   Netflix   Netflix  Kids   Pluto TV  
Rakuten TV  SF Anytime  SkyShowtime  Spamflix  Sun Nxt  Takflix  True Story  TV 2  Viaplay  
WAKANIM  WOW Presents Plus  YouTube Premium 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+  Filmzie  Go3  Google Play Movies  GuideDoc  Hoichoi  Magellan TV  MUBI  Netflix  
Netflix Kids  Spamflix  Sun Nxt  Takflix  True Story  Viaplay  WOW Presents Plus 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+  Filmzie  Google Play Movies  Hoichoi  Magellan TV  MUBI  Netflix  Spamflix  Sun Nxt  
Takflix  True Story  WOW Presents Plus 

Acontra Plus  Acontra Plus Amazon Channel  AcornTV Amazon Channel  Amazon Prime Video  
Amazon Video  Apple iTunes  Apple TV Plus  Argo  Atres Player  BroadwayHD  Chili  Classix  
Crunchyroll    Cultpix    Curiosity  Stream    Dekkoo    Discovery  Plus    Disney  Plus    Dizi  Amazon 
Channel    DocAlliance  Films    DOCSVILLE    Eventive    FilmBox+    Filmin    Filmin  Plus    Filmzie  
FlixOlÃ©    FlixOlÃ©  Amazon  Channel    fuboTV    Google  Play  Movies    GuideDoc    Hayu    Hayu 
Amazon Channel  HBO Max  Historia y Actualidad Amazon Channel  Hoichoi  Lionsgate Plus  
Magellan  TV    MGM  Amazon  Channel    Microsoft  Store    Mitele      Movistar  Plus    MUBI    MUBI 
Amazon  Channel    Netflix    Netflix  basic  with  Ads    Noggin  Amazon  Channel    OUTtv  Amazon 
Channel  Pash Amazon Channel  Planet Horror Amazon Channel  Plex  Pluto TV  Rakuten TV  
rtve    Spamflix    Starz  Play  Amazon  Channel    Sun  Nxt    Takflix    Tivify    True  Story    TVCortos 
Amazon Channel  VIX   WOW Presents Plus  YouTube Premium 

FI 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  Blockbuster  BritBox  BroadwayHD  
C More  Classix  Crunchyroll  Cultpix  Curiosity Stream  Dekkoo  Discovery Plus  Disney Plus  

296 

 
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works in audiovisual media services 

DocAlliance Films  DOCSVILLE  Elisa Viihde  Eventive  FilmBox+  Filmzie  Google Play Movies  
GuideDoc  Hayu  HBO  HBO Max  HBO Max Free  Hoichoi  Hulu  Kirjastokino  Lionsgate Plus  
Magellan TV  Microsoft Store  MUBI  Netflix  Rakuten TV  Ruutu  SF Anytime  SkyShowtime  
Spamflix  Sun Nxt  Takflix  Telia Play  True Story  Viaplay  Viddla  WAKANIM  WOW Presents 
Plus  Yle Areena  YouTube Premium 

Action Max Amazon Channel  Amazon Prime Video  Amazon Video   Anime Digital Networks   
Apple iTunes   Apple TV Plus   Argo   Arte   Bbox VOD   Benshi Amazon Channel   BroadwayHD   
Canal VOD   Canal+   Canal+ SÃ©ries   Cinemas a la Demande   Classix   Crunchyroll   Cultpix   
Curiosity Stream   Dekkoo   Disney Plus   DocAlliance Films   DOCSVILLE   Dogwoof On Demand   
Eventive   FilmBox+   Filmo Amazon Channel   Filmo TV   Filmzie   France TV   Google Play 
Movies   Hayu   Hayu Amazon Channel   Hoichoi   INA  madelen Amazon Channel   Insomnia 
Amazon Channel   La Toile   LaCinetek   Lionsgate Plus   Magellan TV   MGM Amazon Channel   
Microsoft Store   MUBI   MUBI Amazon Channel   myCANAL Apple TV Channel   MyTF1VoD   
Netflix   Netflix basic with Ads   Noggin Amazon Channel   OCS Amazon Channel    OCS Go   
Orange  VOD      Pantaflix      Paramount  Plus      Paramount+  Amazon  Channel      Plex      Pluto  TV   
Rakuten TV   SALTO   Salto Amazon Channel   SFR Play   Shadowz   Shadowz Amazon Channel   
Sixplay   Spamflix   Starz Play Amazon Channel   Sun Nxt   Takflix   Tenk   True Story   Universal 
Pictures      Universcine      Universcine  Amazon  Channel      WAKANIM      WOW  Presents  Plus   
YouTube   YouTube Premium 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+  Filmzie  Google Play Movies  HBO Max  Hoichoi  Horizon  Magellan TV  MUBI  Netflix  
Spamflix  Sun Nxt  Takflix  True Story  WOW Presents Plus  YouTube  YouTube Premium 

All  4    Amazon  Prime  Video    Apple  iTunes    Apple  TV  Plus    Argo    BroadwayHD    Classix  
Crunchyroll  Cultpix  Curiosity Stream  Dekkoo  Discovery Plus  Disney Plus  DocAlliance Films  
DOCSVILLE   Eventive  FilmBox+  Filmzie  Funimation Now  Google  Play Movies  GuideDoc  
Hayu  HiDive  Hoichoi  Lionsgate Plus  Magellan TV  Microsoft Store  MUBI  Netflix  Netflix Kids  
Now TV  Now TV Cinema  Paramount Plus  QFT Player  Rakuten TV  Shudder  Sky Go  Sky 
Store  Spamflix  Sun Nxt  Takflix  True Story  Volta  WOW Presents Plus  YouTube Premium 

Amazon Prime Video  Amazon Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  CG 
Collection Amazon channel  Chili  Cine Comico Amazon Channel  Classix  Crunchyroll  Cultpix  
Curiosity  Stream    Dekkoo    Discovery  Plus    Discovery  Plus  Amazon  Channel    Disney  Plus  
DocAlliance  Films    DOCSVILLE    Eventive    FilmBox+    Filmzie    Full  Action  Amazon  Channel  
Google Play Movies  GuideDoc  Hayu  Hayu Amazon Channel  HistoryPlay Amazon Channel  
Hoichoi  Infinity Selection Amazon Channel  Infinity+  iWonder Full Amazon channel  Lionsgate 
Plus    Magellan  TV    Mediaset  Infinity    MGM  Amazon  Channel    Microsoft  Store    MUBI    MUBI 
Amazon  Channel    Netflix    Netflix  basic  with  Ads    Nexo  Plus    Now  TV    Paramount  Plus  
Paramount+ Amazon Channel  Plex  Pluto TV  Rai Play  Rakuten TV  Serially  ShortsTV Amazon 
Channel  Sky Go  Spamflix  Starz Play Amazon Channel  Sun Nxt  Takflix  Timvision  True Story  
VVVVID  WOW Presents Plus  YouTube Premium 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+  Filmzie  Go3  Google Play Movies  GuideDoc  Hoichoi  Magellan TV  MUBI  Netflix  
Netflix Kids  Spamflix  Sun Nxt  Takflix  Telia Play  True Story  Viaplay  WOW Presents Plus 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+  Filmzie  Go3  Google Play Movies  GuideDoc  Hoichoi  Magellan TV  MUBI  Netflix  
Netflix Kids  Spamflix  Sun Nxt  Takflix  True Story  Viaplay  WOW Presents Plus 

FR 

HU 

IE 

IT 

LT 

LV 

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Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Acorn  TV    Amazon  Prime  Video    Amazon  Video    Apple  iTunes    Apple  TV  Plus    Argo  
BroadwayHD  CineMember  Classix   CONtv   Crunchyroll   Cultpix   Curiosity Stream   Dekkoo  
Discovery Plus  Disney Plus  DocAlliance Films  DOCSVILLE  Eventive  Film1  FilmBox+  Filmzie  
Fox  Google Play Movies  GuideDoc  Hayu  HBO Max  Hoichoi  Horrify  IFFR Unleashed  KPN  
Lionsgate Plus  Magellan TV  meJane  Microsoft Store  MUBI  Netflix  Netflix Kids  NLZIET  NPO 
Start  PathÃ© Thuis  Picl  Rakuten TV  ShortsTV Amazon Channel  SkyShowtime  Sooner  South 
Park  Spamflix  Starz Play Amazon Channel  Sun Nxt  Takflix  True Story  Viaplay  Videoland  
WOW Presents Plus  Ziggo TV 

Acorn  TV    Amazon  Prime  Video    Apple  iTunes    Apple  TV  Plus    Argo    Blockbuster    BritBox  
BroadwayHD  Classix  Crunchyroll  Cultpix  Curiosity Stream  Dekkoo  Discovery Plus  Disney 
Plus  DocAlliance Films  DOCSVILLE  Eventive  FilmBox+  Filmoteket  Filmzie   Google Play 
Movies  GuideDoc  Hayu  HBO  HBO Max  HBO Max Free  HiDive  Hoichoi  Lionsgate Plus  
Magellan TV  Microsoft Store  MUBI  Netflix  Netflix Kids  NRK TV  Pluto TV  Rakuten TV  SF 
Anytime    SkyShowtime    Spamflix    Strim    Sun  Nxt    Takflix    True  Story    TV  2  Play    Viaplay  
WAKANIM  WOW Presents Plus  YouTube Premium 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Canal+  Chili  Classix  
Crunchyroll  Cultpix  Curiosity Stream  Dekkoo  Disney Plus  DocAlliance Films  DOCSVILLE  
Eventive  FilmBox+  Filmzie  Google Play Movies  GuideDoc  HBO Max  HBO Poland  Hoichoi  
Horizon  IPLA  Magellan TV  MUBI  Netflix  NRK TV  Player  Spamflix  Sun Nxt  Takflix  True 
Story  Viaplay  VOD Poland  WOW Presents Plus  YouTube 

Amazon Prime Video  Apple iTunes  Apple TV Plus  Argo  BroadwayHD  Classix  Crunchyroll  
Cultpix    Curiosity  Stream    Dekkoo    Disney  Plus    DocAlliance  Films    DOCSVILLE    Eventive  
FilmBox+  Filmin  Filmin Plus  Filmzie  Google Play Movies  HBO Max  Hoichoi  Magellan TV  
Meo  MUBI  Netflix  Rakuten TV  RTPplay  SkyShowtime  Spamflix  Sun Nxt  Takflix  True Story  
VIX   WOW Presents Plus  YouTube  YouTube Premium 

Amazon  Prime  Video    Argo    BroadwayHD    Classix    Crunchyroll    Cultpix    Curiosity  Stream  
Dekkoo  Disney Plus  DocAlliance Films  DOCSVILLE  Eventive  FilmBox+  Filmzie  HBO Max  
Hoichoi  Horizon  Magellan TV  MUBI  Netflix  Spamflix  Sun Nxt  Takflix  True Story  WOW 
Presents Plus 

NL 

NO 

PL 

PT 

RO 

298 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Annex 6: Non-linear services detailed tables 
on share of European works  EU27 works  
and UK works (Volume 3) 

Share of European works (first definition) – Data retrieved from JustWatch 2023 

Country  All productions 

All European movies 

All European series 

Share of EuropeanWork 

43% 

40% 

29% 

31% 

44% 

37% 

29% 

40% 

35% 

48% 

28% 

27% 

32% 

41% 

30% 

30% 

36% 

36% 

31% 

30% 

35% 

37% 

35% 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

159 983  

  71 901  

  41 682  

  45 579  

224 553  

100 899  

  44 332  

  97 255  

111 892  

170 086  

  39 335  

  46 723  

116 572  

103 244  

  44 338  

  41 782  

  94 044  

106 174  

  62 786  

  54 783  

  26 049  

110 414  

62 659  

27 222  

10 855  

12 939  

89 901  

34 644  

11 724  

35 759  

36 548  

76 361  

10 175  

11 777  

32 383  

39 269  

12 095  

11 330  

30 845  

34 503  

17 081  

15 179  

  8 009  

37 669  

5 771  

1 489  

1 034  

1 039  

9 341  

3 177  

1 044  

3 283  

2 838  

5 365  

    808  

    955  

4 382  

2 956  

1 098  

1 040  

2 769  

4 223  

2 114  

1 274  

1 061  

3 235  

Total 

1 914 406  

658 927  

60 296  

Source: JustWatch 

299 

 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Share of European works (second definition) – Data retrieved from JustWatch 2023 

Country  All productions 

All European movies 

All European series 

Share of EuropeanWork2 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

159 983  

  71 901  

  41 682  

  45 579  

224 553  

100 899  

  44 332  

  97 255  

111 892  

170 086  

  39 335  

  46 723  

116 572  

103 244  

  44 338  

  41 782  

  94 044  

106 174  

  62 786  

  54 783  

  26 049  

110 414  

Total 

1 914 406  

Source: JustWatch 

     50 078  

     21 866  

        8 691  

        9 976  

     72 743  

     26 306  

        9 146  

     27 951  

     26 818  

     62 151  

        7 930  

        8 645  

     24 032  

     30 987  

        9 351  

        8 843  

     22 435  

     25 436  

     12 456  

     11 036  

        6 542  

     28 331  

   511 750  

      5 495  

      1 414  

         975  

         990  

      8 899  

      3 042  

         979  

      3 139  

      2 691  

      5 110  

         765  

         907  

      4 204  

      2 820  

      1 033  

         976  

      2 643  

      4 069  

      2 014  

      1 204  

      1 002  

      3 086  

    57 457  

Share of EU27 works (first definition) – Data retrieved from JustWatch 2023 

 Country   All productions 

All European movies 

All European series 

Share of EUWork 

 159 983  

 71 901  

 41 682  

 45 579  

 224 553  

 100 899  

 44 332  

 97 255  

 111 892  

 170 086  

 39 335  

 46 723  

 116 572  

 103 244  

 48 855  

 21 188  

 7 208  

 8 727  

 70 957  

 24 797  

 7 633  

 27 456  

 25 199  

 63 629  

 6 563  

 7 390  

 18 776  

 30 940  

 3 710  

 962  

 550  

 565  

 6 120  

 1 784  

 576  

 2 142  

 1 444  

 3 740  

 434  

 525  

 912  

 1 904  

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

300 

35% 

32% 

23% 

24% 

36% 

29% 

23% 

32% 

26% 

40% 

22% 

20% 

24% 

33% 

23% 

24% 

27% 

28% 

23% 

22% 

29% 

28% 

27% 

33% 

31% 

19% 

20% 

34% 

26% 

19% 

30% 

24% 

40% 

18% 

17% 

17% 

32% 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

 Country   All productions 

All European movies 

All European series 

Share of EUWork 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

 44 338  

 41 782  

 94 044  

 106 174  

 62 786  

 54 783  

 26 049  

 110 414  

 7 958  

 7 433  

 22 127  

 22 369  

 11 617  

 10 297  

 5 924  

 26 612  

Total 

 1 914 406  

 483 655  

Source: JustWatch 

 606  

 567  

 1 721  

 1 492  

 1 235  

 723  

 557  

 1 629  

 33 898  

Share of EU27 works (second definition) – Data retrieved from JustWatch 2023 

Country  All productions 

All European movies 

All European series 

Share of EUWork2 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

 159 983  

 71 901  

 41 682  

 45 579  

 224 553  

 100 899  

 44 332  

 97 255  

 111 892  

 170 086  

 39 335  

 46 723  

 116 572  

 103 244  

 44 338  

 41 782  

 94 044  

 106 174  

 62 786  

 54 783  

 26 049  

 110 414  

Total 

 1 914 406  

Source: JustWatch 

 36 929  

 16 413  

 5 368  

 6 369  

 54 422  

 17 624  

 5 530  

 20 715  

 16 976  

 49 985  

 4 786  

 5 012  

 11 490  

 23 716  

 5 728  

 5 417  

 15 262  

 14 702  

 8 022  

 7 083  

 4 561  

 3 520  

 911  

 514  

 536  

 5 818  

 1 706  

 535  

 2 041  

 1 358  

 3 534  

 412  

 496  

 817  

 1 806  

 563  

 527  

 1 646  

 1 392  

 1 164  

 675  

 521  

 18 507  

 354 617  

 1 541  

 32 033  

Share of UK works – Data retrieved from JustWatch 2023 

Country  All productions 

All European movies 

All European series 

Share of UKWork 

AT 

BE 

 159 983  

 71 901  

 15 518  

 6 714  

 1 929  

 460  

301 

19% 

19% 

25% 

22% 

20% 

20% 

25% 

26% 

24% 

25% 

24% 

14% 

15% 

27% 

19% 

14% 

23% 

16% 

31% 

13% 

12% 

11% 

25% 

14% 

14% 

18% 

15% 

15% 

14% 

20% 

18% 

18% 

11% 

10% 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Country  All productions 

All European movies 

All European series 

Share of UKWork 

BG 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HU 

IE 

IT 

LT 

LV 

NL 

NO 

PL 

PT 

RO 

SE 

 41 682  

 45 579  

 224 553  

 100 899  

 44 332  

 97 255  

 111 892  

 170 086  

 39 335  

 46 723  

 116 572  

 103 244  

 44 338  

 41 782  

 94 044  

 106 174  

 62 786  

 54 783  

 26 049  

 110 414  

Total 

 1 914 406  

Source: JustWatch 

 3 341  

 4 254  

 21 239  

 11 492  

 3 874  

 9 749  

 13 554  

 15 827  

 3 430  

 4 476  

 15 314  

 10 178  

 3 955  

 3 650  

 10 358  

 12 502  

 5 689  

 5 396  

 2 063  

 12 835  

 195 408  

 437  

 436  

 2 951  

 1 258  

 402  

 997  

 1 275  

 1 503  

 326  

 397  

 3 421  

 976  

 416  

 406  

 968  

 1 749  

 809  

 496  

 448  

 1 472  

 23 532  

9% 

10% 

11% 

13% 

10% 

11% 

13% 

10% 

10% 

10% 

16% 

11% 

10% 

10% 

12% 

13% 

10% 

11% 

10% 

13% 

11% 

302 

 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Annex 7: Audiovisual sector revenues in 
2020, 2021 and 2022 (Volume 2) 

The  below tables show the revenues reported  in  the  audiovisual sector for 2020, 2021, 2022. It should be 
noted that data may not be comparable across years as companies may have reported data only for a specific 
year.  

Revenues generated in the audiovisual sector in 2020 (by country and NACE code) 

J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production 
activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

Austria 

Belgium 

Bulgaria 

Croatia 

€ 116 164 973 

€ 0 

€ 20 589 283 

€ 59 424 693 

€ 1 075 185 392 

€ 28 244 836 

€ 119 378 615 

€ 1 174 819 389 

€ 72 441 809 

€ 51 930 757 

€ 100 582 681 

€ 257 370 423 

€ 75 276 254 

€ 430 085 

€ 56 683 613 

€ 287 968 953 

Czech Republic 

€ 7 234 906 

€ 210 813 671 

€ 432 187 670 

Denmark 

€ 189 937 089 

€ 814 312 

€ 69 004 021 

€ 1 353 841 627 

Estonia 

Finland 

France 

€ 53 278 044 

€ 10 669 361 

€ 8 990 092 

€ 818 902 

€ 526 349 813 

€ 34 464 672 

€ 59 780 801 

€ 246 650 873 

€ 4 429 613 371 

€ 1 122 661 998 

€ 2 676 234 411 

€ 13 042 801 578 

Germany 

€ 1 828 087 564 

€ 322 347 976 

€ 1 973 916 219 

€ 28 288 531 026 

€ 263 757 696 

€ 13 731 285 

€ 153 608 598 

€ 647 224 277 

€ 621 501 971 

€ 48 376 509 

€ 335 859 649 

€ 508 662 043 

€ 133 921 269 

€ 1 175 552 

€ 28 224 860 

€ 364 993 

Greece 

Hungary 

Iceland 

303 

 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production 
activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

€ 1 079 071 770 

€ 320 970 987 

€ 3 550 858 079 

€ 219 847 249 

€ 555 582 153 

€ 9 054 996 853 

€ 29 401 388 

€ 10 549 290 

€ 6 663 143 

€ 76 923 828 

Ireland 

Italy 

Latvia 

Liechtenstein 

€ 1 387 194 

Lithuania 

€ 64 729 917 

€ 4 329 492 

€ 9 087 571 

€ 105 877 329 

Luxembourg 

€ 8 895 132 

€ 5 342 335 

€ 0 

€ 6 996 391 672 

Malta 

€ 0 

Netherlands 

€ 71 401 618 

€ 0 

€ 369 952 902 

€ 1 436 126 957 

Norway 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

€ 691 242 907 

€ 35 631 930 

€ 42 185 364 

€ 1 275 999 685 

€ 466 745 095 

€ 62 576 493 

€ 226 980 902 

€ 2 248 389 381 

€ 356 242 691 

€ 18 935 845 

€ 67 833 259 

€ 2 191 080 249 

€ 442 417 373 

€ 13 845 053 

€ 46 277 538 

€ 304 689 592 

€ 53 897 728 

€ 155 317 946 

€ 14 606 664 

€ 155 596 566 

€ 130 122 156 

€ 3 494 418 

€ 5 596 370 

€ 32 636 670 

€ 2 218 057 835 

€ 337 088 075 

€ 690 267 825 

€ 6 563 312 996 

€ 1 977 207 796 

€ 125 050 184 

€ 275 107 042 

€ 2 805 282 358 

United Kingdom 

€ 33 201 335 591 

€ 1 161 757 932 

€ 8 162 642 131 

€ 18 427 257 262 

Total 

€ 53 735 764 421 

€ 3 788 613 585 

€ 16 607 420 365 

€ 97 975 227 845 

304 

 
 
 
 
 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

Revenues generated in the audiovisual sector in 2021 (by country and NACE code) 

J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production 
activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

Austria 

Belgium 

Bulgaria 

Croatia 

€ 78 010 741 

€ 0 

€ 900 000 

€ 19 232 287 

€ 495 322 167 

€ 11 001 174 

€ 11 295 430 

€ 1 579 595 661 

€ 20 112 095 

€ 11 757 319 

€ 4 342 276 

€ 7 079 142 

€ 115 273 889 

€ 477 631 

€ 65 947 749 

€ 139 223 348 

Czech Republic 

€ 1 596 788 

€ 80 445 

€ 514 108 632 

Denmark 

€ 187 770 355 

€ 794 484 

€ 48 716 786 

€ 895 178 278 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Iceland 

Ireland 

Italy 

Latvia 

€ 60 064 528 

€ 12 071 122 

€ 3 757 543 

€ 5 793 207 

€ 520 228 221 

€ 36 578 613 

€ 64 183 883 

€ 290 329 842 

€ 2 408 596 127 

€ 875 363 559 

€ 1 954 409 095 

€ 14 215 699 750 

€ 1 304 237 969 

€ 233 017 026 

€ 1 137 354 991 

€ 27 214 778 108 

€ 132 805 595 

€ 2 397 153 

€ 143 251 000 

€ 12 445 419 

€ 895 565 131 

€ 56 209 240 

€ 302 410 287 

€ 633 603 265 

€ 36 846 011 

€ 2 437 041 

€ 36 605 252 

€ 243 098 

€ 693 039 486 

€ 38 560 

€ 2 462 449 442 

€ 224 558 496 

€ 166 276 497 

€ 810 876 070 

€ 17 622 843 

€ 1 818 351 

€ 3 818 828 

€ 34 186 033 

Liechtenstein 

€ 0 

Lithuania 

€ 71 507 272 

€ 4 860 904 

€ 5 192 067 

€ 123 629 570 

Luxembourg 

€ 9 398 404 

€ 7 866 667 

Netherlands 

€ 68 748 558 

€ 0 

€ 0 

€ 0 

€ 8 582 441 050 

€ 1 404 185 066 

€ 675 846 947 

€ 33 886 963 

€ 28 399 685 

€ 1 467 604 547 

€ 303 192 060 

€ 32 649 431 

€ 111 377 981 

€ 1 825 296 266 

Norway 

Poland 

305 

 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production 
activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

€ 379 202 183 

€ 21 082 965 

€ 68 208 431 

€ 2 149 370 342 

€ 570 540 056 

€ 17 748 116 

€ 51 060 141 

€ 343 114 089 

€ 57 604 655 

€ 174 716 973 

€ 15 233 279 

€ 181 007 102 

€ 99 218 839 

€ 6 817 357 

€ 5 497 573 

€ 29 036 858 

€ 966 999 075 

€ 105 053 777 

€ 807 098 040 

€ 4 476 577 042 

€ 1 499 983 096 

€ 62 079 964 

€ 129 054 821 

€ 2 750 350 402 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United Kingdom 

€ 21 202 089 132 

€ 1 069 131 124 

€ 5 050 276 434 

€ 17 193 153 696 

Total 

€ 35 333 871 665 

€ 3 004 375 450 

€ 10 214 787 074 

€ 86 898 138 170 

*No data was reported for Malta for 2021. 

Revenues generated in the audiovisual sector in 2022 (by country and NACE code) 

J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production 
activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

Austria 

Belgium 

Croatia 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

Czech Republic 

€ 1 280 622 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

€ 722 353 

€ 108 722 

€ 0 

€ 4 740 

€ 20 029 597 

€ 1 223 000 

€ 1 295 000 

€ 105 000 

€ 15 161 799 

€ 259 045 552 

€ 782 474 406 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

Denmark 

Estonia 

Finland 

France 

Germany 

306 

 
 
 
 
 
 
 
 
 
 
Study on the implementation of the provisions of the revised AVMSD concerning the promotion of European 
works in audiovisual media services 

J59.1.1 - Motion 
picture video and 
television 
programme 
production 
activities 

J59.1.2 - Motion 
picture video and 
television 
programme post-
production 
activities 

J59.1.3 - Motion 
picture video and 
television 
programme 
distribution 
activities 

J60.2 - Television 
programming and 
broadcasting 
activities 

€ 34 483 

€ 0 

€ 23 200 

€ 0 

€ 0 

€ 23 988 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

€ 0 

€ 2 921 112 

€ 5 176 574 

€ 17 382 578 

€ 3 583 824 

€ 7 770 

€ 208 444 

Hungary 

Ireland 

Italy 

Lithuania 

Luxembourg 

Netherlands 

Norway 

Slovakia 

Spain 

Sweden 

United Kingdom 

€ 1 117 554 897 

€ 121 914 519 

€ 42 742 685 

€ 913 254 333 

Total 

€ 1 172 213 517 

€ 388 796 729 

€ 831 696 435 

€ 913 572 517 

Source: Orbis Europe 

*No data was reported for Malta for 2021. 

307 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Getting in touch with the EU 

In person 

All over the European Union there are hundreds of Europe Direct centres. You can find the 
address of the centre nearest you online (european-union.europa.eu/contact-eu/meet-
us_en). 

On the phone or in writing 

Europe Direct is a service that answers your questions about the European Union. You 
can contact this service: 

–  by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls), 
–  at the following standard number: +32 22999696, 
–  via the following form: european-union.europa.eu/contact-eu/write-us_en. 

Finding information about the EU 

Online 

Information about the European Union in all the official languages of the EU is available on 
the Europa website (european-union.europa.eu). 

EU publications 

You can view or order EU publications at op.europa.eu/en/publications. Multiple copies of 
free publications can be obtained by contacting Europe Direct or your local documentation 
centre (european-union.europa.eu/contact-eu/meet-us_en). 

EU law and related documents 

For access to legal information from the EU, including all EU law since 1951 in all the 
official language versions, go to EUR-Lex (eur-lex.europa.eu). 

EU open data 

The portal data.europa.eu provides access to open datasets from the EU institutions, 
bodies and agencies. These can be downloaded and reused for free, for both commercial 
and non-commercial purposes. The portal also provides access to a wealth of datasets 
from European countries. 

308 

 
 
K
K
-
0
5
-
2
4
-
1
4
1
-
E
N
N

-

309