CISAC, GESAC and SAA Support Complaints by Bulgarian Authors’ Societies on EU Copyright Breaches

CISAC, together with GESAC and the SAA, has written to the European Commission expressing support for the complaints submitted by Bulgarian authors’ societies FILMAUTOR and MUSICAUTOR regarding Bulgaria’s ongoing non-compliance with EU copyright law.

In their joint letter to Emmanuelle du Chalard, Head of the Copyright Unit at the European Commission, the three organisations highlight the systemic dysfunction of Bulgaria’s Copyright and Related Rights Law, which has left collective management organisations (CMOs) unable to obtain government approval for tariffs — a legal precondition for licensing rights and collecting royalties on behalf of authors and rightsholders.

Despite the existence of a formal procedure, repeated failures by the Bulgarian authorities to act have created a legal vacuum in which works are exploited without authorisation or remuneration. Between 2019 and 2024, all five tariff procedures initiated by FILMAUTOR, MUSICAUTOR and PROPHON ended without a decision by the competent commission, illustrating a chronic dysfunction in the system.

The letter cites breaches of several provisions of Directive 2014/26/EU, including the obligation to ensure appropriate remuneration for rightsholders (Article 16.2) and the requirement to provide effective dispute resolution mechanisms (Article 35). As a result, Bulgarian authors have been unable to update or enforce tariffs for more than two decades, depriving creators both in Bulgaria and across the EU of fair compensation.

CISAC, GESAC and SAA have called on the European Commission to urgently investigate the complaints and take the necessary measures to ensure Bulgaria brings its national legislation into full compliance with EU law.