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TONO to the EU:
TONO has submitted a comprehensive contribution to the EU Commission's evaluation of the Copyright Directive (DSM Directive). “One of the main challenges is that technology companies are not open about how music is used in the training of artificial intelligence,” says Inger Elise Mey of TONO.
/ 17/06/2026 / Willy MartinsenThe Digital Single Market Copyright Directive (DSM Directive) was adopted in 2019. The European Commission is now conducting a major evaluation of how it works in practice and what challenges have arisen since 2019.
– This is the largest framework we have in Europe in the areas that matter most to our members now, that is, licensing of music in digital media and platforms, as well as frameworks for AI and copyright, says Inger Elise Mey, Director of International Affairs at TONO.
Inger Elise Mey was in the driving seat when TONO last week submitted TONO's input to the EU Commission regarding the ongoing evaluation. It has been particularly important to highlight what developments in artificial intelligence mean for authors and rights holders, she says.
– Yes, we see clear signs that copyrighted music and song lyrics are being used in the development of AI systems, without there being transparency about the scope or basis for payment. This is serious and there is an urgent need for the EU to address this issue now. This has been a core message in our submission.
A common theme in TONO's input is the lack of transparency into how AI companies collect and use training data.
Today, neither authors nor management organizations have any real way of knowing whether their works have been used in the development of artificial intelligence.
“The biggest challenge is simply that we don't know what's happening. Without transparency, it's impossible to enforce rights or establish well-functioning licensing schemes,” says Mey.
TONO points out in its submission to the EU that this creates significant challenges for both enforcement, licensing and payment to authors.
TONO also warns that the development could have direct consequences for authors' income. Generative artificial intelligence can already produce music that resembles existing works, and is being used in an increasing number of contexts where licensed music was previously used.
– When AI-generated music can in practice replace human-created works in the market, it challenges the entire basis for how creators get paid, says Mey.
At the same time, TONO emphasizes that the organization is not against technological development, but that development must occur within clear rights systems.
Norway has not yet implemented the DSM Directive into national legislation, making it difficult to provide a concrete assessment of how the regulations work in practice in the Norwegian market.
– We have therefore had to respond more fundamentally, and point out how we believe the regulations should work. At the same time, it is important that Norwegian perspectives are also heard in this process, says Mey.
TONO has also collaborated closely with European sister organizations in its work, including through GESAC.
The evaluation of the DSM Directive is part of a larger effort in the EU to adapt the regulations to new technologies and markets. TONO's input will be included in the EU Commission's assessment of how the directive works in practice.
TONO also plans to provide input into the work on new regulations related to artificial intelligence, where the EU Commission has recently requested input from market players.
“These are processes that will have great significance for creators in the years to come. Therefore, it is important that we participate actively and promote their interests,” says Mey.
