Response to the Public Consultation on the Evaluation of the Audiovisual Media Services Directive: Downstream Title-Level Observability, Sanctions Compliance, and Structural Gaps in the EU Audiovisual Ecosystem

Supplementary analytical note submitted to the European Commission's public consultation on the evaluation of the Audiovisual Media Services Directive (AVMSD, Directive 2018/1808). Filed via EUSurvey on 23 March 2026. This submission identifies a structural gap in the current AVMSD evaluation framework: the absence of downstream title-level observability across EU audiovisual distribution chains. It argues that without standardised, machine-readable reporting at the title level—covering licensing, territorial availability, and beneficial ownership—the Directive cannot effectively monitor market concentration, enforce sanctions compliance (particularly Council Regulation (EU) 2022/879 and subsequent measures),…