- Automated ex ante content blocking, removal or monitoring tools present high risks to human rights, such as freedom of expression, information and access, and their abuse may hinder creativity.
- The necessity and proportionality of these tools should be subject to clear and objective conditions, deep assessment and transparent public oversight.
- As Article 13 is currently framed, it is excessively broad, it may reach platforms that should not be subject to any ex ante control provision, and it may also render smaller players and projects economically and operationally inviable.
- If the purpose of Article 11 of the reform is to protect the conventional press publishing business models, policy-making initiatives must provide evidence that the proposed model is more efficient and that the proposed trade-off will be reasonable.
- The implications and the impact of ‘snippet’ protection is not clear and should be thoroughly analysed by policy makers and civil society, the reform should also carefully address the excessive concentration of press power.