A Green Paper on AI, Data Governance, and Metadata Policies for Europe’s Music Ecosystem

Practical Steps Towards a Decentralised and Open European Music Observatory

Author
Affiliation

Daniel Antal, CFA

Reprex

Published

May 12, 2026

Introduction

There are musical works that are reinterpreted thousands of times across centuries. A symphony by Beethoven or a folk song from the Baltic coast can be heard again and again, each performance offering a new reading of something that never becomes “final.” The same is true of sound recordings: some are rediscovered decades later, remastered, and brought back into circulation for new audiences.

Music assets, in other words, have an unusually long lifecycle. This is equally true of their documentation — the metadata that accompanies them from creation to archiving. Metadata does not freeze a work or recording in time. Instead, it evolves alongside it: from the moment of rights registration, through commercial distribution and playlisting, to preservation in a library or archive. Each new interpretation, remix, or reissue generates new metadata, and each new information system demands new connections and contexts.

This Green Paper builds on a substantial body of prior European policy analysis concerning copyright data, metadata interoperability, and the implications of new technologies for the cultural and creative sectors. In particular, it draws on the Study on copyright and new technologies: copyright data management and artificial intelligence, commissioned by the European Commission (DG CNECT) and published in 20221.

That study identified persistent structural weaknesses in rights metadata management across creative industries, including the music sector, despite long-standing identifier systems and standardisation efforts. These weaknesses include fragmentation between identifiers and registries (ISRC, ISWC, ISNI, VIAF, IPI), limited interoperability between sectoral systems, high administrative costs in rights management, and difficulties in ensuring authoritative, machine-readable information across the full lifecycle of creative works and recordings.

The study further noted that emerging technologies, including artificial intelligence, are increasingly deployed in environments where metadata quality and legal clarity are insufficient, amplifying existing inefficiencies and legal uncertainties. It therefore emphasised the need for lifecycle-aware metadata governance, improved integration of existing standards and identifiers, and institutional arrangements that enable trust, transparency, and interoperability rather than further centralisation. These findings form an important analytical baseline for the policy considerations and implementation examples discussed in this Green Paper.

NoteWhy this Green Paper matters for music professionals?

  • Streaming has centralised power in platforms, while leaving rightsholders with micro-royalties and growing administrative burdens.

  • Metadata mistakes translate directly into lost revenue — each unlinked ISRC or ISWC is money left unclaimed.

  • AI is already reshaping music ecosystems: it can either support documentation and remuneration, or flood systems with untracked works.

  • Europe needs federated, cooperative solutions so independents, collective management organisations, and heritage institutions can compete on fairer terms.

There is rarely a single moment when music metadata can be considered complete. Metadata, like music itself, is open to reinterpretation. A name may later be reconciled with an identifier; a work may be linked to a new performance; a recording may be embedded in new formats or platforms. Each act of documentation adds layers of meaning and makes music intelligible in new environments.

This is not an invitation to reinvent the wheel. We can still read Beethoven’s early prints as well as Iris Szeghy’s twenty-first-century scores because music notation — a standardised way of expressing the metadata of musical works — has remained remarkably stable for centuries. Notation demonstrates that standardisation can endure, and that shared conventions make music legible across time, geography, and institutions.

In Slovakia, we implemented, using the European Interoperability Framework for shared digital services, public-private service integration to make music more visible and its handling more cost efficient. Our implementation aligns well with the requirements set by the Copright Infrastructure Task Force.

The invention of the computer, and later the internet, introduced new ways to document and transmit music. A recent scholarly analysis building on the Open Music Europe research and innovation framework further elaborates these dynamics, highlighting that rights-related metadata is both the most economically consequential and the most difficult to establish and maintain in fragmented legal and institutional environments.

These innovations brought powerful efficiencies: identifiers such as the ISRC and ISWC, digital distribution pipelines, and networked catalogues enabled the global circulation of music at unprecedented scale. At the same time, they produced new fragmentation. Standards proliferated, identifiers failed to interconnect, and attempts to create comprehensive registries repeatedly failed, reflecting not only technical constraints but deeper institutional fragmentation and misaligned incentives across stakeholders. (Bodo 2026)

Note

This Green Paper is a policy document developed within the Open Music Europe (OpenMusE) Horizon Europe Research and Innovation Action (Grant Agreement No. 101095295). It deliberately combines policy research with implementation piloting, ensuring consistency with the legal and policy framing established in Deliverable D5.6 while testing its implications in real-world data environments.

Prepared in line with the Guidelines for Open Policy Analysis (available at https://www.bitss.org/opa/community-standards/) and the Horizon Europe Data Management Guidelines. The document has been released early to support consultation, incorporate stakeholder input, and ensure transparency throughout its development. It extends the analysis developed in the first OpenMusE policy brief on music metadata mainstreaming and EU law (Deliverable D5.6), and its core findings are further condensed in the second policy brief (Deliverable D5.7), which integrates wider stakeholder consultations2.

Transparency note: This Green Paper does not present a purely conceptual or speculative policy proposal. Substantial parts of the analysis synthesise lessons from policy-embedded implementation activities conducted using Open Policy Analysis methods, including openly documented data, code, workflows, and methodological decisions. These activities were carried out in cooperation with public authorities and sectoral institutions, allowing the paper to reflect both policy ambitions and real-world constraints.

In accordance with Open Policy Analysis principles3, all related deliverables and technical documentation are publicly accessible to foster engagement and ensure a clear audit trail. The current version (and future White Paper drafts) is available at https://zenodo.org/records/17075796. Standardised folders, figures, and bibliographies are available at https://github.com/dataobservatory-eu/open-music-data-white-paper.

This document situates the Open Music Observatory as a central reference point. The Observatory is a prototype of a modern European Music Observatory developed by the OpenMusE consortium, currently populated with data on economy, diversity, society, and innovation, and operating multiple federated modules. Technical documentation and versioned DOIs are available via Zenodo, with an overview at https://openmusicobservatory.eu/.

Funding acknowledgement: This project has received funding from the European Union’s Horizon Europe programme under Grant Agreement No. 101095295. The views expressed are those of the authors only and do not necessarily reflect those of the European Commission or its agencies4.

Citation note: When citing this Green Paper, please use the latest versioned DOI available on Zenodo, and include the date of access if referring to material hosted on our GitHub repository.5 This is an early version (0.9.6.)

You can visit the Open Music Observatory on https://openmusicobservatory.eu/. For API-level access get in touch with Reprex.

Our document has been presented and discussed with industry specialists on the following forums:

  • Big Data Value Association, Gaia-X: Dataweek²⁴: Introducing a new European music dataspace6
  • Echoes/ECCH: The ECHOES (European Cloud for Heritage OpEn Science) policy even and workshop, 12-13 December 2024 at the Royal Institute for Cultural Heritage (KIK-IRPA), Brussels,
  • Hungarian stakeholders interested in replication of the Slovak pilot versions in various meetings throughout 2024 and 20257.
  • CISAC: Protecting Creators’ Rights in the AI Era: OpenMusE at the European Committee Meeting, Vilnius, 29-30 April 8.
  • The Fair MusE - Prelude to a fairermusic industry Fair MusE project9
  • IAMIC 10: The International Association of Music Information Centres and several key members of the organisation.
  • IAML: The International Association of Music Libraries, Archives and Documentation Centers and several national chapters and key members 11.
  • Polifonia: In October 2023 Polifonia invited a few stakeholders - Podiumkunst.net, the Open Music Observatory, Uni Firenze, IC Fonseca School, Joséphine Simonnot/PRISM, Maria Luisa Onida/D’Istruzione Superiore Leonardo Da Vinci, Carnegie Hall Archive, Municipality of Bologna - for a work session, which gave us a great opportunity to strengthen the metadata framework of our policy recommendations and infrastructure planning. At this stage, we started to record user stories for the design of system competences of the Open Music Europe software ecosystem and the observatory’s semantic architecture12.
  • Music Futures: the AHRC Creative Industries Cluster project MusicFutures in the United Kingdom.
  • Slovak national stakeholders interested in cultural data.13
  • Wikimedia community and developers14.
  • European music industry stakeholders on LineCheck 2025 15

This Green Paper is aligned with the European Commission’s Culture Compass for Europe and its ambition to strengthen shared European cultural data infrastructures. It proceeds from the premise that cultural data challenges are largely shared across domains, but that effective implementation requires domain-specific, federated units where sectoral complexity exceeds what generic frameworks can capture. Music is one such domain.

The analytical conclusions of the Study on copyright and new technologies subsequently informed further work at Member State and European levels, including the establishment of the Copyright Infrastructure Task Force (CITF). The CITF First Project Report (Ministry of Education and Culture, Finland, 2025) translates the study’s findings into a set of infrastructure-oriented requirements for trustworthy, machine-readable copyright data in the AI era, focusing in particular on identifiers, rights management information, provenance, and federated governance.

This Green Paper approaches the same structural challenges from a music sectoral perspective. Drawing on implementation pilots developed within the Open Music Europe (OpenMusE) project, it examines how the kinds of infrastructures envisaged by CITF can operate in practice in the music ecosystem — a domain characterised by fragmented governance, mixed public–private data environments, and complex lifecycle metadata.

Because of this complementarity, the main chapters of this document are deliberately structured to mirror CITF’s layered approach. The 2  Fixing Music Data at the Source reflects the foundational layer (authoritative identifiers and repairable rights metadata); the 3  Open Music Observatory: Building a Shared Music Data Space corresponds to the semantic and technical layers (federated registries, mappings, and interoperability profiles); and the 4  AI that Works for Music, Not Against It translates AI-era infrastructure requirements into music-specific governance questions. In this sense, CITF provides the horizontal policy framework, while this Green Paper offers a domain-level reference implementation that can inform broader European copyright infrastructure discussions 16.

  1. Study on copyright and new technologies: copyright data management and artificial intelligence (SMART 2019/0038) (European Commission et al. 2022)↩︎

  2. The Policy Brief 1: Music Metadata Mainstreaming and EU Law (Senftleben et al. 2024) provides the primary legal and institutional framing on which this Green Paper builds and which it operationalises through a lifecycle-oriented and implementation-focused approach. The present Green Paper builds on that foundation with a lifecycle- and sovereignty-oriented conceptual framework, tested in pilots such as the Slovak Comprehensive Music Database. Its key recommendations are further condensed in OpenMusE Policy Brief 2: An Open, Scalable Data-to-Policy Pipeline for European Music Ecosystems (Deliverable D5.7, 2025) (Open Music Europe Consortium 2025), which integrates broader stakeholder consultations (CISAC, IAMIC, IAML, FairMusE, Music360, ECCCH forums, among others) and translates them into policy actions for EU institutions. The political economy of the open music metadata ecosystem—and the impact of the Spotify hack offers a scholarly overview of this work (Bodo 2026).↩︎

  3. The Guidelines for Open Policy Analysis form an actionable and practical set of directives that the OpenMusE consoritum was mandated to use under the Grant Agreement. It can be seen as good implementation framework for Evidence-based policy making in the European Commission and The practice of reproducible research [BITSS (2019); Open Music Europe (2023); (J 2015; Kitzes, Turek, and Deniz 2018).↩︎

  4. This document has been prepared by Open Music Europe (OpenMusE) project partners as an account of work carried out within the framework of this contract. Any dissemination of results must indicate that it reflects only the author’s view and that the Commission Agency is not responsible for any use that may be made of the information it contains. Neither Project Coordinator, nor any signatory party of Open Music Europe (OpenMusE) Project Consortium Agreement, nor any person acting on behalf of any of them:
    (a) makes any warranty or representation whatsoever, express or implied, (i) with respect to the use of any information, apparatus, method, process, or similar item disclosed in this document, including merchantability and fitness for a particular purpose, or (ii) that such use does not infringe on or interfere with privately owned rights, including any party’s intellectual property, or (iii) that this document is suitable to any particular user’s circumstance; or
    (b) assumes responsibility for any damages or other liability whatsoever (including any consequential damages, even if advised of the possibility) resulting from your selection or use of this document or any information, apparatus, method, process, or similar item disclosed herein.↩︎

  5. Always use the latest versioned DOI when citing this Green Paper, available via Zenodo. If you rely on supporting material hosted in the GitHub repository, please add the date of access in your reference. The figures and charts can be found on FigShare and may be reused separately, citing their DOI and, for context, the Green Paper that contains them.↩︎

  6. Jun 5, 2024, Dataweek²⁴, Leuven, Belgium.↩︎

  7. Federation possibilities of the Slovak music data sharing space in Hungary (Antal 2024a)↩︎

  8. Protecting Creators’ Rights in the AI Era: OpenMusE at the European Committee Meeting, our presentation (Mikš 2025)↩︎

  9. We received useuful feedback for this Green Ppaer from the project and see further synergies in presenting our policy findings together. https://fairmuse.eu/about/↩︎

  10. We presented and discussed these ideas at the International Association of Music Information Centres on the General Assembly and Annual Conference 2024 on November 21, 2024, at Music Austria, Vienna. See the presentation and its poster format (Antal 2024c, 2024d).↩︎

  11. We presented and discussed these ideas at the International Association of Music Libraries, Archives and Documentation Centers on the General Assembly and Annual Conference 7th and 9th of July 2025 in Salzburg, Austria. See the presentation and its poster format (Antal 2025a, 2025b).↩︎

  12. The user stories were placed in an OPA compliant folder on GitHub. This work was not carried on after the initiated grant agreement change, when the WP4 did no longer participate in building open source software for this purpose, but we did not abandon the competency requirements (Open Music Europe Consortium 2023).↩︎

  13. Based on a memorandum of understanding with a broad range of public and private stakeholders, (Ministerstvo kultúry SR and Open Music Europe 2023) we developed a model for renewing statistical production for better cultural and music statistics (Antal 2023).↩︎

  14. Our work was presented in the Technology session of the Wikimedia CEE Meeting 2024 in Istanbul, and the Wikimedia CEE Meeting 2025 in Thessaloniki, and the Wikidata Conf 2025 online; we have built relationships with various national chapters and the Wikidata and Abstract Wikipedia teams, and joined the Wikidata Ontology Cleanup Task Force and the Wikidata Mereology Task Force to help the coordiantion of our open source technology, data curation and dissemination efforts. (Antal 2024b, 2025c; Antal, Pigozne, and Federico 2025).↩︎

  15. Open Access Music Dataspaces – Open Music Observatory presented on LineCheck 2025 (Mikš and Antal 2025)↩︎

  16. Since November 2025, members of the Open Music Europe team have participated in the expert group of the Copyright Infrastructure Task Force (CITF). The OMO and its federated national modules are intended to serve as a practical music sectoral use case for the scaling of federated copyright data infrastructures within the CITF framework, including its planned activities for 2026–2027.↩︎