This time we have a heavyweight report for you. EVERYTHING is going on.

In Denmark your face and voice will soon be protected by copyright.
Meanwhile in Brussels, all levels of the EU are hotly discussing child
protection, its brewing. Oh yes, and simplification is also very hot right
now. The EU is under pressure to simplify its rulebooks.

Welcome to a busy rentrée, brought to you by WMEU :)


=== Denmark Copyrights Faces ===

Denmark’s parliament is expected to pass a bill that extends copyright
protections to personal characteristics, such as voices and faces. It will
include a protection against the sharing of realistic digitally generated
imitations of people’s personal characteristics. In parallel, there will be
a second protection for performers and artists against the sharing of
realistic digitally generated imitations of their performances. There will
be a solid majority in parliament for this and we expect it to become law
by the end of the year.

—

Wikimedia Denmark has participated in the public consultation
<https://dk.wikimedia.org/wiki/H%C3%B8ring/H%C3%B8ring_over_forslag_til_lov_om_%C3%A6ndring_af_lov_om_ophavsret_(Indf%C3%B8relse_af_en_pr%C3%A6stationsbeskyttelse_og_beskyttelse_mod_digitalt_genererede_efterligninger_mv.)>,
pointing out that the exceptions and limitations foreseen in the draft
proposal would be insufficient to protect all current users on Wikimedia
projects.

—

Apart from this, the Communia Association
<https://communia-association.org/2025/08/21/communias-submission-to-the-danish-consultation-on-the-proposal-for-introducing-protection-against-digitally-generated-imitations-in-copyright-law/>
for the Public Domain and Professor Bernt Hugenholtz
<https://communia-association.org/2025/08/21/communias-submission-to-the-danish-consultation-on-the-proposal-for-introducing-protection-against-digitally-generated-imitations-in-copyright-law/>
from the University of Amsterdam, have additionally questioned the wisdom
of using copyright to achieve this otherwise laudable policy goal.

—

At a Copyright & AI conference
<https://danish-presidency.consilium.europa.eu/en/events/conference-on-copyright-and-artificial-intelligence/>
in Copenhagen organised by the Danish Council Presidency, that Dimi
attended, the Danish Minister of Culture was quite proud of the project.
Ministry officials admit that it might not be the perfect solution, but
also doubt that a perfect solution exists. Their reasoning for using
copyright is that it already has an existing framework for content
moderation that includes notices, liability rules, exceptions, and free
speech protections.

=== More Copyright & AI ===

Speaking of copyright and AI, there is a parliamentary own-initiative
report
<https://oeil.secure.europarl.europa.eu/oeil/en/procedure-file?reference=2025/2058(INI)>in
the works, penned by MEP Axel Voss (EPP DE) as rapporteur. It is
non-legislative, so it will be essentially a document with a list of
statements that a majority can agree on. Voss himself is suggesting that AI
generated content should be public domain. There is also plenty of talk
about how smaller organisations can negotiate their rights vis-à-vis
operators of large language models, with collective licensing agreements
being floated.

—

Currently amendments are being analysed and discussed in commission. They
are expected to be considered on 13 October, a committee vote is scheduled
for early December. The plenary vote is expected in January.

== Child Protection ===

In the Council, the Danish Council Presidency is working on a declaration
on online safety. From what we have seen it will include language asking
for age verification for "social media and all other relevant digital
services that pose a significant risk to minors". The open question here is
which platforms exactly are meant by this. Declarations are non-binding in
nature, but are often used to build political momentum ahead of legislative
proposals.

—

In the Parliament, there is an own-initiative report on child protection
online, led by digital powerhouse lawmaker Christel Schaldemose (S&D DK).
It is currently in the drafting phase with compromises being negotiated.
The rapporteur is suggesting that the report demands age verification
mechanisms, not just age assurance, for social media and video-sharing
platforms. It also demands harmonisation, including on age limits. We will
see which of these demands get a majority, as criticism is pouring in from
both left and right, albeit for different reasons: privacy, national
competence and parental prerogatives. Such reports are non-legislative and
non-binding, but serve to test majorities.

—

The largest political group in the parliament, and the one holding almost
all important positions of power, the EPP, is working on its “digital
position paper”. It is expected to demand age verification for online
gambling and pornography. It also calls for a harmonised minimum age of 16
for the use of social media and video-sharing sites, in the absence of
parental consent. The latter, according to the draft, could be achieved
with age assurance measures. We will wait to see the final product.

—

The President of the European Commission, Ursula von der Leyen, included
child protection in her annual speech to the parliament. She
name-checked Australia’s
social media restriction for users under 16 based on age as a positive
example and shared that she plans to commission a panel of experts to show
the way forward.

=== CSAM Regulation ===

We have written about the proposal on fighting Child Sexual Abuse Material
online
<https://en.wikipedia.org/wiki/Regulation_to_Prevent_and_Combat_Child_Sexual_Abuse>
many times in this newsletter (and about the WMF position
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12726-Fighting-child-sexual-abuse-detection-removal-and-reporting-of-illegal-content-online/F3338612_en>).
The European Parliament has a good negotiating mandate
<https://www.europarl.europa.eu/news/en/press-room/20231110IPR10118/child-sexual-abuse-online-effective-measures-no-mass-surveillance>,
defending privacy by not mandating the scanning of all direct messages on
all messaging services. The Council’s position is still not agreed upon,
which is why the file is still stuck.

—

The development is that in mid-October there will be a vote of the
Justice/Home Affairs Ministers. The Danish Council Presidency wants to
remove the deadlock with a new compromise text
<https://data.consilium.europa.eu/doc/document/ST-10131-2025-INIT/en/pd>.
The text has attracted significant criticism, mainly for fears that this
proposal would break end-to-end encryption. If the Council manages to agree
on a position, they will start negotiations with the European Parliament.

=== Simplification ===

The European Commission is looking for new targets to propose
simplification, i.e. to cut bureaucracy or reduce regulatory burden. After
the GDPR burden reduction proposal, which will reduce record keeping
obligations for organisations smaller than 750 staff and which the WMF
welcomes
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14700-Burden-reduction-and-simplification-for-competitiveness-of-small-mid-cap-enterprises-Omnibus-Regulation/F3593069_en>,
they have now turned their attention to the so-called digital omnibus. It
is with a focus on data, cybersecurity and artificial intelligence and
the public
consultation is ongoing
<https://digital-strategy.ec.europa.eu/en/news/commission-collects-feedback-simplify-rules-data-cybersecurity-and-artificial-intelligence-upcoming>
.

—

Simultaneously, the Commission is also reviewing how the Digital Services
Act interacts and overlaps with  other laws and rules. It is also taking a
second look at VLOP-specific rules, such as designation and calculation of
thresholds. This could be of interest to Wikipedia, which is a VLOP under
the DSA.

—

The work on simplification is accelerated by very strong language from
national capitals, including Germany
<https://www.politico.eu/article/friedrich-merz-vows-stick-in-the-wheels-of-brussels-machine-overregulation/>
and Sweden
<https://www.linkedin.com/posts/luca-bertuzzi-186729130_in-july-swedens-prime-minister-ulf-kristersson-activity-7377236716539248640-htTl?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAeproUBXNqHN69Lk4Kqhg9eynIXTdLelns>
most recently, to focus on competitiveness and re-start the economy.

=== Do Paço ===

If you read the public policy list, the César do Paço saga will not have
escaped you. The Wikimedia Foundation is now going to the European Court of
Human Rights to contest the decision by the Portuguese court to hand over
user data and remove some content. Jacob Rogers from WMF Legal has written
up an excellent explanation
<https://medium.com/wikimedia-policy/what-happened-in-the-c%C3%A9sar-do-pa%C3%A7o-lawsuit-f91b7fb5e54b>
of the entire, multi-year development.

=== Data Retention for Criminal Proceedings ===

There is currently no harmonised EU regime with regards to criminal
proceedings that specifies which metadata service providers should keep and
for how long. The Commission has run a public consultation
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14680-Data-retention-by-service-providers-for-criminal-proceedings-impact-assessment_en>
on this and the Wikimedia Foundation, as a service provider, provided
feedback
<https://drive.google.com/file/d/1ywq0eb14s-3j9m8omIVz4mMGw6ZbW7_P/view?usp=sharing>.
Broadly speaking, the position is that data retention affects human rights
and the public interest and that broader and longer data retention
obligations would risk harming these. The WMF also cites its experience in
this area, including cases such as the above (Do Paço).

=== European Research Act ===

The European Commission is running, yet another, public consultation
on the European
Research Area Act
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14608-European-Research-Area-Act_en>.
Wikimedia Sverige stepped in
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14608-European-Research-Area-Act/F3713161_en>
and provided public feedback. The key arguments made are that open access
to research results is crucial for the dissemination of accurate
information to the public, including through Wikimedia projects. It also
outlines how researchers are often hindered by significant legal and
technical barriers and makes the case for a broad research exception.

=== Civil Society Engagement ===

Not to be outpaced, Wikimedia Deutschland also provided feedback at the EU
level recently. There was a consultation on the EU’s Civil Society Strategy
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14588-EU-Civil-Society-Strategy_en>
and how to address the shrinking civic space for civil society. In its
feedback
<https://docs.google.com/document/d/1qGKN1Lw2Y7Dula3kDOaNEwR8ptVOhu1g/edit?usp=sharing&ouid=110641574264354613563&rtpof=true&sd=true>
WMDE emphasises the role of volunteers and the need to protect their
rights, as well as to support community based models.

=== European Competitiveness Fund ===

The EU is discussing
<https://www.consilium.europa.eu/en/meetings/compet/2025/09/29/?utm_id=3318>
its 2028-2034 long-term budget (a.k.a. the multiannual financial framework,
MFF). Perhaps the main instrument in it is the European Competitiveness
Fund (€409 billion are proposed).

—

The trick with such gigantic funds is that in the end no one really knows
what exactly to do with the money. They have all these keywords written
into their regulation, but what exactly are projects that could deliver? In
the case of the ECF
<https://data.consilium.europa.eu/doc/document/ST-11770-2025-INIT/en/pdf>
we can find terms like open-source, digital public infrastructure,
sovereignty, competitiveness, and simplification.

—

Instead of arguing about five billion more here or there, and about whether
to use the term “digital public good” instead of “digital public
infrastructure” (just a made up example), it might be refreshing to skip
the meta-level and to concretise the conversation a little with concrete
examples of past funded projects that worked and such that didn’t. Just an
idea.

=== END ===

-- 
Wikimedia Europe ivzw
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