A coalition of specialty streaming platforms has taken its concerns directly to Brussels, warning European Commission officials that the bloc's audiovisual rules are being applied in ways that punish editorial focus and could ultimately reduce the range of content available to viewers across Europe.

Beyond Mainstream: A Global Streaming Alliance submitted an open letter on March 9, 2026, to Henna Virkkunen, Executive Vice-President for Tech Sovereignty, Security and Democracy at the European Commission. Copied on the letter were Roberto Viola, Director-General of DG CONNECT; Renate Nikolay, Deputy Director-General of DG CONNECT; and Anna Herold, Head of Unit for Audiovisual and Media Services Policy within DG CONNECT. The coalition made its letter public on March 10, 2026, through a formal press release.

The alliance, which was launched in November 2025, represents platforms operating across global markets. Its membership includes AMC Networks' Acorn TV, ALLBLK, HIDIVE, Shudder, and Sundance Now; Crunchyroll; Golf Central; Lightning International; NDM+; OUTtv; Pure Flix; Rakuten Viki; The Roku Channel; SonyLiv; Sony One; Tubi; and Zee5. These are services defined not by breadth of catalogue but by curatorial identity - genre-focused, linguistically targeted, or built around specific communities and cultural expressions.

The structural complaint

The letter's central argument is blunt. According to Beyond Mainstream, the Audiovisual Media Services Directive (AVMSD) contains proportionality mechanisms that exist in the text of the law but are rarely applied in practice. The result, the coalition argues, is a regulatory framework that treats all on-demand services as variations of the same model - large, multi-genre, globally scaled platforms - when the reality of the market is far more varied.

"The streaming landscape has diversified significantly since the AVMSD's last revision," the coalition wrote, "yet the policy lens has largely remained focused on traditional broadcasters and large, multi-genre platforms. This creates a blind spot, not in the AVMSD's text itself, but in how it is applied by Member States."

That distinction matters. The coalition is not challenging the existence of the directive or calling for deregulation. It is specifically criticising the gap between what the framework permits and what national authorities actually do.

The AVMSD requires on-demand services operating across the European Union to ensure that at least 30% of their catalogue consists of European works. Some Member States have set thresholds higher than this minimum. A growing number have also introduced financial contribution obligations, each with their own thresholds, scope definitions, and exemptions. For a mainstream streaming platform with tens of thousands of titles spread across genres and languages, meeting a 30% European works quota is a manageable exercise. For a service with a focused catalogue built around, say, Japanese anime or South Asian cinema, the same obligation is structurally different in character.

According to Beyond Mainstream, when obligations designed for broad-catalogue platforms are applied uniformly to a service with a focused editorial identity, "the effect is not proportionate regulation. It is a structural penalty on editorial focus."

Accessibility and localisation compound the problem

Content quotas are only part of the picture. The letter draws attention to a second layer of compliance pressure: accessibility and localisation obligations under the AVMSD.

Article 7 of the directive establishes an EU framework for disability accessibility, while Articles 13, 16 and 17 address cultural diversity. However, according to the coalition, national transpositions vary considerably and frequently exceed these minimum standards. The practical requirements can include mandatory dubbing, extended subtitling obligations, audio description quotas, and prescriptive technical specifications. Each of these carries direct cost implications.

For a large platform, these requirements represent a manageable proportion of operating costs. For a specialised service with a narrower catalogue and limited scale, the burden is proportionally far heavier - particularly, the coalition notes, "when driven by regulatory mandate rather than demonstrated audience demand."

The letter highlights an additional problem: inconsistency across Member States. A specialised service may qualify for an exemption in one country while facing disproportionate obligations in another for the identical catalogue. According to Beyond Mainstream, the consequences are predictable: compliance costs multiply, legal certainty erodes, and market entry becomes harder. The practical outcome is fewer services and less content diversity for European audiences - the opposite of what the directive is intended to achieve.

This fragmentation, the letter argues, also undermines the coherence of the Digital Single Market itself.

What the coalition is requesting

The letter contains four specific asks. First, the coalition calls on the Commission to acknowledge specialised streaming services as a distinct category in the ongoing AVMSD evaluation, rather than treating all on-demand services as variations of the same model. Second, it requests interpretive guidance on the application of the low-audience and low-turnover exemptions, which currently exist in the directive but are applied unevenly across Member States.

Third, Beyond Mainstream asks the Commission to ensure that thematic exemptions are applied consistently and systematically across all Member States. The coalition notes that the Commission issued guidelines on low audience and turnover thresholds in 2020, but has never issued comparable guidance on thematic exemptions. According to the letter, "the absence of any Commission guidance on thematic exemptions, in contrast to the 2020 guidelines on low audience and turnover thresholds, has left this provision largely unused despite its clear legislative intent."

Fourth, the coalition calls for a structured dialogue with specialised services during the evaluation process - a seat at the table that, it argues, has historically been occupied almost exclusively by the largest platforms.

The coalition registered on the EU Transparency Register under number 0083815102257-62.

Voices from coalition members

Several members provided public statements alongside the press release. Gita Rebbapragada, Chief Operating Officer of Crunchyroll, framed the problem in operational terms. "While the regulatory landscape evolves beyond a one-size-fits-all model, AVMSD legislation could still end up inhibiting specialised platforms like Crunchyroll compared to mainstream platforms," she said. "Our aim is to celebrate fan communities with unique content, and we respectfully ask the Commission to consider a framework that reflects and protects platform diversity so that we can avoid any disruption to consumer experience."

Brad Danks, CEO of OUTtv Media Global, pointed to the direct impact on service availability. "For specialised streaming services like ours, national localization and compliance standards can create disproportionate burdens that ultimately limit content availability," Danks said. OUTtv currently distributes in several EU Member States and has stated intentions to expand further across Europe. Danks expressed hope that the Commission would apply obligations "more proportionately, enabling specialised streamers to broaden their offerings to more EU audiences."

A spokesperson for Zee Entertainment Ltd offered broader framing: "As the media landscape evolves, it is essential that regulation recognizes the diversity of platforms and avoids a one-size-fits-all approach that may unintentionally hinder innovation. A proportionate and equitable framework will not only safeguard industry growth but also ensure that viewers continue to benefit from a vibrant and competitive ecosystem."

Prior advocacy: the Québec precedent

The Brussels letter is not the coalition's first regulatory intervention. Beyond Mainstream submitted a separate letter to Québec policymakers in December 2025, focusing on Bill 109, formally titled "An Act to Affirm the Cultural Sovereignty of Québec and to enact the Act Respecting the Discoverability of French-language Cultural Content in the Digital Environment."

The coalition acknowledged the intent behind the Québec legislation, writing: "We share the Québec government's commitment to preserving the province's rich culture and understand policymakers' desire to make it easier for Quebecers to discover and access original French-language cultural content. We believe, however, that certain provisions of Bill 109 could have unintended negative consequences."

The Québec intervention covered similar ground to the Brussels letter: concerns about a one-size-fits-all approach, potential reductions in viewer choice, and vagueness in the regulations that creates overlap with federal policy. The pattern across both interventions suggests the coalition is building a consistent regulatory argument for deployment across jurisdictions.

Context: streaming regulation and the European advertising market

The coalition's letter arrives at a moment of broader tension between EU regulatory ambition and the operational realities of digital media businesses. The European Media Freedom Act took effect in August 2025, adding another layer to the audiovisual regulatory framework. Meanwhile, the European Commission has been working on simplifying digital rules more broadly, opening a public consultation in September 2025 on a digital omnibus package targeting reduced administrative burden.

Research has documented how regulatory complexity affects market dynamics. A study published in June 2025 by the National Bureau of Economic Research found that GDPR compliance costs - estimated at approximately 16 billion euros annually for European companies - have reshaped investment patterns in ways that may have permanently weakened Europe's ability to compete in the global digital economy. The Beyond Mainstream coalition is arguing that a similar logic applies to smaller-scale digital media services caught in regulatory frameworks designed for larger operators.

For the advertising community, the stakes are practical. European streaming data released in 2025 by the European Audiovisual Observatory revealed that viewing concentration on major platforms is substantial, with audiences spending the majority of their streaming time on a small percentage of available content. Specialty platforms serve the long tail of audience demand - the segments that mainstream services do not prioritise. If regulatory compliance costs force those services to exit European markets, or prevent new ones from entering, the advertising inventory associated with those niche audiences disappears with them.

Tubi, one of the Beyond Mainstream coalition members, reached 97 million monthly active users as of January 2025 and integrated with Google's Display & Video 360 in March of that year, illustrating how free ad-supported streaming services from the specialty segment have become meaningful components of the programmatic advertising ecosystem. The Roku Channel, another member, represents similar scale within the ad-supported streaming tier. Regulatory pressure that constrains these platforms' European operations carries implications not just for content availability but for the advertising inventory available to brands targeting specific audience segments.

The European digital advertising market reached €118.9 billion in 2024, a 16% increase that included remarkable growth in streaming video formats - subscription video on demand platforms recorded 222.4% growth in advertising revenue as major services expanded their advertising capabilities. That expansion has been concentrated at the top of the market. Specialty platforms, by definition, serve the segments that fall outside the mainstream. Their regulatory treatment will determine whether that advertising inventory continues to exist.

Why this matters for marketing professionals

The AVMSD review is not typically a topic that registers strongly in advertising industry discussions. Most regulatory attention in digital advertising has focused on the Digital Services Act, the Digital Markets Act, and GDPR enforcement - all of which affect the mechanics of ad targeting and data processing. The AVMSD operates upstream of those mechanisms, shaping which services exist and what audiences they can reach.

If the coalition's argument holds - that uniform application of European works quotas and localisation obligations creates structural penalties for services with focused editorial identities - the downstream consequence is a narrower range of streaming environments in which advertisers can reach specific audience segments. Anime fans, South Asian diaspora audiences, LGBTQ+ viewers, and faith-based content consumers all represent distinct demographic clusters with purchasing power. The platforms that currently serve them are precisely the ones flagging compliance risk in Brussels.

The coalition's registration on the EU Transparency Register, its engagement on multiple continents, and the seniority of the executives providing public statements all indicate this is a sustained lobbying effort with meaningful resources behind it. Whether the Commission's evaluation of the AVMSD will formally distinguish specialised services as a separate regulatory category remains to be seen. The coalition's letter frames the ask in modest terms - applying existing flexibility provisions consistently, issuing interpretive guidance, establishing a dialogue. But the underlying argument, that the current framework structurally disadvantages a growing segment of the streaming market, has implications for how the audiovisual regulatory landscape develops across Europe and beyond.

Timeline

  • November 4, 2025 - Beyond Mainstream: A Global Streaming Alliance officially launched, uniting fifteen specialty streaming platforms with audiences in nearly every country
  • December 10, 2025 - Beyond Mainstream submitted a letter to Québec policymakers on Bill 109, the Act to Affirm the Cultural Sovereignty of Québec, raising concerns about unintended consequences for specialty streamers
  • March 9, 2026 - Beyond Mainstream submitted an open letter to Henna Virkkunen, Executive Vice-President of the European Commission, addressing the application of the AVMSD to specialised streaming services; Roberto Viola, Renate Nikolay, and Anna Herold at DG CONNECT were copied
  • March 10, 2026 - The coalition published a press release making the letter public and releasing statements from coalition members including Crunchyroll COO Gita Rebbapragada, OUTtv CEO Brad Danks, and a spokesperson for Zee Entertainment Ltd

Summary

Who: Beyond Mainstream: A Global Streaming Alliance, a coalition of seventeen specialty streaming platforms including Crunchyroll, Tubi, The Roku Channel, OUTtv, Pure Flix, Rakuten Viki, SonyLiv, Zee5, and AMC Networks' Acorn TV, ALLBLK, HIDIVE, Shudder, and Sundance Now.

What: The coalition submitted an open letter to the European Commission calling on policymakers to address how the Audiovisual Media Services Directive is applied to specialised streaming services. The letter requests that the Commission acknowledge specialised platforms as a distinct regulatory category, issue interpretive guidance on low-audience and low-turnover exemptions, apply thematic exemptions consistently across all EU Member States, and establish a structured dialogue with specialty services during the AVMSD evaluation process.

When: The letter was dated March 9, 2026, and made public via press release on March 10, 2026. The coalition was founded on November 4, 2025, and had previously submitted a separate letter to Québec policymakers on December 10, 2025.

Where: Brussels, addressed to the European Commission's DG CONNECT directorate, with simultaneous public release via press release distributed to media. The coalition also addressed Canadian regulatory issues through its Québec intervention.

Why: According to the coalition, the uniform application of AVMSD obligations - including a 30% European works catalogue quota, financial contribution requirements, mandatory dubbing, extended subtitling, and audio description quotas - creates structurally disproportionate burdens for services defined by editorial focus rather than breadth of catalogue. The coalition argues that existing proportionality mechanisms in the directive are not being applied consistently across Member States, resulting in compliance cost multiplication, legal uncertainty, and barriers to market entry that could reduce content diversity and viewer choice across Europe.

Share this article
The link has been copied!