France Digitale’s Answer to the targeted initiative for a better copyright environment for European creativity and innovation
EUROPE
France Digitale contributed to the EU's review of the CDSM Directive, representing European AI companies across the value chain. Its message: Europe's sovereignty depends on access to diverse, high-quality data reflecting its own culture, but the Article 4 opt-out mechanism too often restricts startups' access. France Digitale calls for a balance between innovation and a thriving creative ecosystem.
France Digitale is pleased to have contributed to the European Commission’s review of the CDSM Directive. Our members represents European AI Companies, operating across the entire value chain, from chips makers, to cloud providers, model providers to deployers. Having actively contributed to the debate on AI and copyright over the past two years, including through a dedicated study on the topic, we welcome the opportunity to formally share our perspective.
Our contribution is guided by a simple principle: Europe must ensure that AI developers can access the high-quality data needed to build competitive technologies on the continent, while preserving a thriving creative, cultural, and media ecosystem.
Digital sovereignty has become a cornerstone of European industrial policy. Yet discussions around AI competitiveness often focus on computing power, semiconductors, energy infrastructure, and talent, while overlooking a critical component of the AI value chain: data. Without access to large volumes of diverse, high-quality data, Europe will struggle to develop competitive AI models and maintain its technological autonomy. More importantly, Europe’s cognitive sovereignty depends on ensuring that AI systems are trained on data that reflects our languages, cultures, values, and societal realities. Otherwise, we risk becoming increasingly reliant on technologies shaped by perspectives that are not our own.
While we strongly support maintaining an effective Text and Data Mining exception for AI training, we also highlight the limitations of the current opt-out mechanism under Article 4 of the CDSM Directive, which can significantly restrict European startups’ access to data and undermine innovation. France Digitale stands ready to engage constructively in this important debate. Europe must create the right conditions for innovation to flourish while preserving an environment where creativity, information, and the exchange of knowledge remain accessible, dynamic, and open, rather than increasingly fragmented, restricted, or proprietary.