The long-term viability of radio is at risk: open letter from radio broadcasters on the regulation of user interfaces under the EMFA

A coalition of radio broadcasters wrote an open letter calling EU’s trialogue negotiators for urgent regulation of user interfaces under article 19.


Stefan Möller, President of the AER, said: “the EMFA is a crucial opportunity to enshrine in legislation the support that EU lawmakers recognise is necessary to secure the future of radio and ensure a level playing field between the tech platforms and licensed radio broadcasters.

Radio is now part of a much wider digital and audio entertainment market. Listeners have more ways of listening than ever before. While broadcast radio still reaches big audiences, user interfaces and connected devices are growing rapidly and providing an explosion of choice. And innovation will not stop. We are on a long-term trajectory of continuous innovative disruption, which makes more and more important to focus on securing the future of radio and our distribution on connected devices and infotainment systems.

With these changes happening, and online listening growing, licensed radio broadcasters are provided with new opportunities to improve their offer to listeners and advertisers. The flip side of the coin is that radio is competing on a much bigger playing field where big techs dominate the market. They provide competing services but also control our route to market through connected devices and user interfaces, which makes radio more difficult to find.

We, at the AER supports the main objectives of the EMFA to promote the independence and pluralism of media in Europe, and in order to do so, it should not forget the essential public value role of radio, providing millions of European citizens with trusted and reliable information, companionship and entertainment daily. We want discoverability and findability to be embraced as core objectives in the EMFA that enable listeners to find, choose and engage with content that is otherwise difficult to access and find. So far, article 19 of the EMFA has, regrettably, failed to address that.

In times where user interfaces and connected devices control what content European citizens can have access to, listeners must be allowed to easily find, discover and access the radio content of their choice. EU lawmakers must act now and provide strong, meaningful and future-proof measures in the EMFA that secure the future viability of radio, ensuring audio content services from licensed radio broadcasters are granted appropriate discoverability and are easy to find. This is the only way to protect media pluralism, cultural diversity and our democracy.”

Read the full joint letter below.



4th December 2023

EU lawmakers can play a significant role in boosting media pluralism and democracy in Europe by safeguarding the findability and discoverability of licensed radio stations. Decisive action from EU lawmakers regarding the European Media Freedom Act (EMFA) is now urgently required. Without this, the long term viability of radio is at risk.

As a collective of business leaders from some of Europe’s most-loved commercial radio broadcasters and audio streaming players, reaching well over 200 million weekly listeners across the European Union, we are very concerned about the future of radio as a medium, a trusted, reliable, editorially independent and culturally enriching companion, a social compass in a digital era plagued by disinformation and other forms of online harms. By adhering to high ethical and professional standards, the hundreds of journalists we employ play a key role in combatting fake news, misinformation and disinformation across Europe.

The radio industry is alive to the opportunities that disruptive innovation can bring. As consumers grow accustomed to new ways of listening, we see the opportunity for a new wave of digital innovation, benefitting listeners, radio broadcasters and advertisers alike, bringing higher levels of consumer choice and empowerment, new routes to market and a more pluralistic audio landscape, including through the provision of trusted news bulletins to millions of EU citizens.

At the same time, radio’s growing reliance on “user interfaces” (including connected car infotainment systems), has enormous potential to be a significant threat if one of the fastest growing routes to market for radio is effectively owned and controlled by a handful of third parties with significant market power and influence who are able to act as ‘intermediaries’ and custodians of valuable audience data. Without fair access to such data, radio broadcasters’ ability to develop competing products and generate new revenue streams is stymied.

The stakes are high. For radio businesses to remain viable in this new environment, their output needs to be available on all platforms and findable by listeners.

Thus far, the representations we have made to the European Parliament and Council on this matter have been drowned out by discussions on some of the more contentious aspects of the EMFA proposal, but with urgent and decisive action EU lawmakers still have an opportunity to support the essential contribution radio makes to media pluralism and democracy. This can most effectively be achieved by regulating the findability and discoverability of licensed radio stations under article 19 of the EMFA.

In the absence of clear and robust rules, providers of user interfaces may interfere with the free flow of information by engaging in practices that control, restrict or obstruct the ability of audiences to find media content. For example, providers of user interfaces may treat their own content services preferentially (or the content services of partners that pay for preferential treatment). This may occur with or without the knowledge of those audiences. All of this puts the viability of radio and, in turn, the free formation of opinion that is underpinned by (inter alia) editorially independent radio stations, at risk, endangering our democracies.

As we approach the end of the trilogue negotiations, we hope that EU lawmakers will take heed of our urgent call to secure media plurality in the audio sector over the long term, so that the EMFA doesn’t turn out to be an empty promise!

Download the PDF here


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