Brussels, 7th July 2025

• Over 200 independent record labels and trade associations have raised significant concerns about Universal Music Group’s acquisition of Downtown Music Holdings.
• Deal is the latest in a line of serial acquisitions from UMG in the independent sector.
• Together they have signed an open letter to the European Commission calling for a detailed investigation (“phase two”) to be opened.

A coalition of leading European and international independent music companies and trade associations have issued an open letter to Executive Vice-President Teresa Ribera at the European Commission, urging the Commission to conduct a deep investigation of Universal Music Group’s (UMG) proposed acquisition of Downtown Music Holdings. 

The letter – signed by more than 200 CEOs, founders and business leaders across the independent music industry – highlights serious concerns that the acquisition would threaten the effective competition, innovation, and growth of the EU’s music industry, further entrenching UMG’s already significant market power. UMG is already the world’s largest music company, controlling more than 40% of the recorded music market in Europe – nearly twice the share of its nearest competitor¹.

Downtown Music Holdings operates world leading distribution platforms FUGA and CD Baby (the DIY platform for artists) as well as the biggest royalty accounting service Curve and Songtrust (the DIY platform for composers). While major labels such as UMG often carry out these services in-house, most independent labels, publishers and artists rely on these types of services to distribute their music to streaming services, track royalties, manage rights, and to get paid accurately.

This deal is also the latest in a long line of serial acquisitions from UMG in the independent sector, having recently acquired PIAS, 8Ball Music, Hyperion, Outdustry and Oriental Star Agencies, among others.

The letter warns that the acquisition of Downtown would place “a significant chunk of essential infrastructure under the control of the market leader”, forcing many independent companies to rely on their biggest competitor to connect artists and their music to fans.

They argue that this deal “would reduce choice for consumers, stifle experimentation, and undermine Europe’s role as a vibrant incubator of musical and artistic expression.” They advocate that “we must keep music open” to support a thriving music ecosystem that delivers benefits for the economy, culture and innovation.

The full letter and signatories is available below.

Executive Vice-President Teresa Ribera
European Commission
Rue de la Loi / Wetstraat 200
1049 Brussels
Belgium

4 July 2025

Dear Ms. Ribera,

We are the founders and CEOs of leading European and international music companies as well as trade associations. We normally write about music and culture and today we are also reaching out about competition.

On behalf of the independent music community, we are writing to express our serious concerns regarding the proposed acquisition of Downtown Music Holdings LLC (“Downtown”) by Universal Music Group N.V. (“UMG”), currently under investigation by the European Commission – Case M.11956.

The music industry in the EU is a cultural and economic success story, with recorded music revenue growing at 8.7% in 2023 and valued at €5.2 billion². It is home to some of the most recognisable names in music, alongside thriving independent businesses.

But we can’t take this for granted. While the EU’s music industry is indeed growing, this growth is uneven and lags behind other global markets. At the same time, changes are being made to how streaming revenues are shared, over which the independent sector has no say. A level playing field is essential to support a thriving music ecosystem that delivers benefits for the economy, culture and innovation.

Everyone has a role to play – from the biggest music company in the world to the independent disruptive start-up uncovering new genres and sounds. But when acquisitions like this one occur and start to tip the scales too far, we must act.

The proposed acquisition by UMG represents a serious risk to that balance. Across Europe, UMG already controls over 40% of the recorded music market – near double the second biggest player³. By absorbing Downtown’s distribution, royalty accounting, and rights management capabilities – services used by thousands of companies and artists across the independent sector – UMG would further entrench its already significant market power.

The deal would place a significant chunk of essential infrastructure under the control of the market leader. Many independent music businesses are already tied to Downtown’s services, meaning that we would have to rely on our biggest competitor to connect our artists and their music to their fans.

That’s why it’s critical that the deal is reviewed through the lens of its “control share” over the digital markets economy, as well as the physical market, not just share by revenue.

This isn’t just a simple “investment” in one of the world’s most prominent independent companies; it is about control.

The implications are profound. This consolidation would further enable UMG to act as a gatekeeper to some of the sector’s best services, shaping which music is heard, promoted, and monetised. Such power carries risks not only to the commercial fortunes of independent businesses, but to the creative breadth and diversity of music itself.

A concentration of this magnitude would narrow the range of voices, styles, and cultures that reach the public. It would give UMG further power to shape digital services, influence monetisation thresholds and extract more, at the expense of the independent sector. That would reduce choice for consumers, stifle experimentation, and undermine Europe’s role as a vibrant incubator of musical and artistic expression. Fans will hear less of the new and more of the same. Artists working outside the commercial mainstream will struggle to find traction. And a once-thriving creative economy will begin to stagnate.

This acquisition also provides a key competitive advantage by allowing UMG to collect data from rivals using its services. This data is far reaching, from distribution information – including artists and song trends, and performance on digital platforms – all the way through to critical business information such as pricing, contractual terms and strategic relationships. Being able to access all of this data would give UMG backdoor access to other competing businesses in the market and strengthen its already advantageous position even further.

Independent music companies play a vital role in promoting music innovation, fostering diversity and protecting culture. To fulfil that role, we must have fair and non-discriminatory access to the best infrastructure in the music economy. And not be forced into structural dependence on our biggest competitor who is also shifting payment models on digital services.

We therefore urge the European Commission to open a detailed phase two investigation to examine the deeper structural consequences of this transaction. The proposed acquisition poses a clear threat to effective competition, innovation, and the growth of the music industry across the EU and globally.

We must keep music open.

Sincerely,

Ludovic Le Strat, President, 23.23
Manuela Nikele, General Manager, 375 Media GmbH
Ed Horrox, Managing Director, 4AD
Cecilia Crespo, General Manager, A.S.I.Ar – Asociación de Sellos Independientes de Argentina
Dr. Richard James Burgess MBE, President and CEO, A2IM – American Association of Independent Music
Felippe Llerena, Director, ABMI – Associação Brasileira da Música Independente
George Seay, Owner, Acrophase Records
Petra Deka, Head of Publishing, ACT Music+Vision GmbH+CO.KG
Magnus Bjerkert, CEO, Adrian Recordings
Gee Davy, Chief Executive, AIM – Association of Independent Music
Joe Clarke, Interim Chair, AIM Ireland – Association of Independent Music Ireland
Maria Amato, CEO, AIR – Australian Independent Record Labels Association
Toni Verona, President and General Manager, Alabianca
Sam Valenti, Co-CEO; CEO, All Flowers Group; Ghostly Intl
Sergi Roig Torrubiano, Director – Chief Officer, Altercat records
Cormac O’Halloran, Director, Always The Sound
Joana Negrão, , AMAEI – Associação de Músicos Artistas e Editoras Independentes
Ruth Koleva, President, ANMIP-BG – Association of Independent Music Publishers and Producers in Bulgaria
Andrzej Dąbrowski, Board Member, ANPM – Alians Niezależnych Producentów Muzycznych
Boris Horvat, Director, Aquarius Records
Sebastian Cowan, Owner, Arbutus Records
Petra Reiter, Manager, Artist Factory Music
Stéphane Laick, Cofounder, AT(h)OME; FELIN – Fédération Nationale des Labels et Distributeurs Indépendants
Pär Winberg, Owner, Atenzia Records
Lars Leverenz, Head of Label, Audiolith
Marco Rossi, Owner, Azzurra Music
Johann Günther, Founder, Backlash Music
Arne Thamer-Steinwärder, Co-Founder & CEO, Backseat PR & Labelservices
Christoph Hallerberg, PR & Coaching, Backseat PR & Labelservices
Sebastian Król, Founder, Backseat PR & Labelservices
Mathieu Dassieu, CEO, Baco Music
Karl Bader, CEO , Bader/Molden Recordings
Kai Florian Becker, Founder – Label Manager, Barhill Records
Katie Garcia, Founder, Bayonet Records
Martin Mills, Chair, Beggars Group
Paul Redding, CEO, Beggars Group
Nils Kacirek, Musician, Bello Neon Records
Dan Waite, CEO, Better Noise
Danny Akalepse, Owner & Musician, Big Crown Records
Leon Michels, Owner; Musician & Producer, Big Crown Records; El Michels Affair
Miguel Angel Sancho, Director, Blau Producciones
Dietmar Hoscher, Founder, Blind Rope Records
Jeremy Lascelles, CEO and Co-Founder, Blue Raincoat Music/ Chrysalis Records
Hadi El Azzi, Chairman, BMYD – Bağımsız Müzik Yapımcıları Derneği
Randy Melibajew, Managing Director, Book of Raw GmbH
Henrietta Bauer, CEO / Managing Director, Bretford Records / What Is Happening? I Feel It Everywhere! GmbH
Phil Hill, Owner & Founder, Cargo Independent Distribution
Dario Giovannini, Managing Director, Carosello Records
Liza Bantegnie, Cofounder, Cartelle
Anne-Laurence Chambon, Director, Carton Records; Maison Tempête
Ester Petri, Managing Director, Carus-Verlag GmbH & Co. KG
Jeff Bratton, Owner, Cascine
Ben O’Connor, Label Manager, Chapter Music
Guy Blackman, Label Manager, Chapter Music
Andrew Cash, President and CEO, CIMA – Canadian Independent Music Association
Christof Ellinghaus, Founder – CEO, City Slang
Ian Ilavsky, Co-Owner, Constellation
Martin Goldschmidt, Co-Founder and Chairman, Cooking Vinyl
Jordi Freixa, Director, Cooperativa Montgri
Alexander Gramlich, Founder, copaseDisques
Robert Litsen, CEO, Cosmos Music
Simon Platz, Managing Director, Cube Records Ltd
Eduardo Jordão, General Manager, CultManagement Lda.
Bianca Eysenbrandt, Owner, Dackelton Records
Dario Draštata, Executive Director, Dallas Records; RUNDA – Regional Association of Independent Discographers in Adria
Javer Tomas Y Tio, General Manager, Darlalata
Phil Waldorf, Co-CEO, Dead Oceans
Borja Torres, Music Supervisor, Discos Buenos
Antonio Céspedes Pérez, Director General, División Sonora Producciones
Ricardo Fernández Arroyo, Communication Director, División Sonora Producciones
Clare Whitlock, Director Commercial & Business Affairs, Domino Recording Company Ltd.
Laurence Bell, CEO, Domino Recording Company Ltd.
Nigil Mack, CEO, drink sum wtr
Verena Boessmann, Co-Owner, Dunstan Media
Manuel Sanz, Director, Ecléctica Records/ Ecléctica Management
Dr. Sabine Meier, Managing Director, Edition Roland Musikverlag GmbH
Pierangelo Mauri, Founder, Edizioni ZYX Music; Net’s Work’s & Songs
David Aguado, Director, El Tragaluz
Denis Kappes, Co-owner, Eliterecords
Dario Raimondi, Founder – Label Manager, Energy Production
Ines Collarte, Director, Entrebotones
María Pellicer Lara, Director, Eo Música
Roger Dorresteijn, Managing Director, Epitaph Europe
Enrique Perea, A&R, Everlasting Records
Mark Kitcatt, Co-owner & chair, Everlasting Records; Popstock
Charles Caldas, Partner, Exceleration Music
Patrick Tilg, Producer, Feberwolle
Björn Mathes, Co-Founder / CEO, FerryHouse GmbH & Co. KG
Adeline Ferrante, Publishing director, Fougue
Marcus Herbert, Label Manager, From Lo-Fi to Disco!
Silvana Battisti, Label Manager, From Lo-Fi to Disco!
Serafino Perugino, Founder, Frontiers Records
Ian Westley, Co-Owner, Full Time Hobby Music LTD
Nigel Adams, Co-Owner, Full Time Hobby Music LTD
Carl-Fredrik Häggqvist, CEO, Owner, Gazell Records AB
Nenad Borovčak, CEO, Geenger Records
Pavle Eftimovski, Managing Partner, Glitch Records
Chris Eckman, CEO, Glitterbeat Records
Alexander Waldron, Owner & CEO, Greco-Roman Ltd
Simon Kessler, Director, Greenpiste Records
Lenz Hein, Label Manager, Grönland
Louise Sansom, Director, founder, Hidden Track Records
Louis Posen, President, Hopeless Records
Per Faeltenborg, CEO, Hot Stuff AB/Svenska Energy Rekords & Publishing AB
Aymeric Genty, CEO, I.O.T Records
Stephen O’Malley, Label Owner, Ideologic Organ
Pascal Bittard, CEO, IDOL 
Francisca Sandoval, President, IMICHILE – Asociación Gremial Industria Musical Independiente de Chile
Dylan Pellett, General Manager, IMNZ – Independent Music New Zealand
Helen Smith, CEO, IMPALA – European association of independent music companies
Katja Vauhkonen, Executive Director, Indieco – Suomen riippumattomien levy- ja tuotantoyhtiöiden yhdistys
Anca Lupes, Executive Director, INDIERO – Asociatia a producatorilor si editorilor de muzica independenti din Romania
Andreas Ryser, Founder, IndieSuisse – Association of Swiss independent music labels and producers
Alexandre Cazac, Artistic director, cofounder, InFiné
Hannes Tschürtz, Founder & Managing Director, Ink Music
Pedro Marques, Director, Invict Sound & Vision
Darius Van Arman, Co-CEO, Jagjaguwar; Secretly Distribution
David Morel, Director, Jarring Effects
Calvin Johnson, Founder, K Records
Tom Nieuweboer, CEO, K7!
Lio Cerezo, Owner / A&R, Kanine Records
Tony Presley, Label Manager, Keeled Scales
Rajk Barthel, Founder – Owner, Kick The Flame Publishing GmbH
Gilles Dutrève, Director, La Granges à Sons
Isabella Viertbauer, Founder, Label 4
Peter Cronemeyer, Owner, Laika-Records
Daryl Fidelak, Founder, Lampshade Media
Andreas Jantsch, CEO & Founder, Las Vegas Records
Helmut Heuer, Owner, Légère Recordings
Tanja Michaelis, Founder – Managing Director, Made_in_Germany – music GmbH
Robert Stieler, Owner – Managing Director, Major Label
Zsolt Jeges, Founder, Mamazone Records; HAIL – Hungarian Association of Independent Labels
Mats Hammerman, CEO, Massproduktion i Sundsvall AB
Chris Lombardi, C-founder, Matador
Gerard Cosloy, Co-founder, Matador
Patrick Amory, Co-founder, Matador
David Buder, Co-Founder & CEO, Matches Music
Oliver von Felbert, Founder, A&R and label manager, Melting Pot Music GmbH
Mac McCaughan, CEO, Merge Records
Mik Christensen, Label Manager and Partner, Mermaid Records
Jorge Otero, Director, Meseta Records
Anders Mörén, Owner, Misty Music AB
Adam Weisman, Musician, Mixed Salad
Walter Gröbchen, CEO, Monkey Music
Marta Sampaio, Manager, Monster Jinx
Miran Rusjan, Founder, Moonlee Records
Theresa Langner-Schibranji, Founder, Morinoko
Larry Bringsjord, CEO, Owner, MTG Music; FONO – Norwegian Association for Independent Record Labels
Javier De Esteban, CEO, Music Adders
Annalea Bertelsen, Board Member, Music For Dreams
Geert De Blaere, Founder – Owner, N.E.W.S. nv; BIMA – Belgian Independent Music Association
Carol von Rautenkranz, Managing Partner, Napa Sounds GmbH
Mario Limongelli, Founder, Nar International PMI – Produttori Musicali Indipendenti
Neil Grant, Founder – Manager, Neil Grant Media & Promotion
Bruno Cariou, Director, Neomme
Elin Trogen, CEO, NONS Records
Jon Madsen, Managing Director, Nordic Music Society
Christian Pliefke, Founder, Nordic Notes / CPL-Musicgroup
Derek Birkett, Director, One Little Independent Ltd
Beatriz Concepcion, Director, Oso Polita
Vittorio Cigala, Managing Director, OYEZ!
Dagobert Böhm, Director, Ozella Music
Ciaran Conroy, Co-CEO, Paragon Records
Brian Scally, Co-CEO, Paragon Records
Andy Widder, Founder, Part Records / Rockin‘ Rollin‘ Products
Mario Rossori, Founder, Pate Records
Vedran Meniga, CEO, Pdv Records
Maria Romana Trainini, Managing Director, Peer Southern Productions
Fabian Burbano, Director, Play Abc Sl/Abc Music
Jonas Sjöström, Chairman and Founder, Playground Music Scandinavia
Johan Alm, co-owner, PNKSLM Recordings AB
Matthias Broeckel, Director, PORK PIE
Mathias Schwarz, Managing Director, Powerline Agency OHG
Martin Koller, Owner, ProMedia GmbH
Stefan Groß, Owner, Q-rious Music
Axel Franzén, Owner, Rama Lama Records
Daniel Meteo, Founder & Co-Owner, Random Musick Publishing GmbH
Eva Pyko, Managing Director, Random Musick Publishing GmbH
Riku Paakkonen, Founder & Managing Director, Ranka Kustannus
Paulina Parvanov, CEO, Raspberry Soda
Elaine McCann, Head of Label, Reckless Records
Nelly Santamarta, Owner & Chair, Registros de Cultura
Eva Santamaría Molina, Publishing Manager, Republic Network Oü
Etienne Tricard, Cofounder, Rescue + Return Records
Anne-Flore Levacher, Head of projects, Roche Musique
Geoff Travis, Founder, Rough Trade
Jeanette Lee, Founder, Rough Trade
Jeff Casazza, Owner / A&R, Run For Cover
Matt Werth, Owner/CEO, RVNG Intl
Caleb Braaten, Founder, Sacred Bones Records
Branko Paić, Managing Director, Scardona
Henrik Guemoes, Managing Director, Schubert Music Publishing GmbH
Nuno Saraiva, Founder-Director, SCL / Lusitanian
Justin West, CEO, Secret City Recordings
Ben Swanson, Co-CEO, Secretly Canadian
Chris Swanson, Co-CEO, Secretly Group
Filip Lundgren, CEO, Septembernatt
Eva Wilke, CEO, Owner, Silence AB
Barbara Preisinger, Founder – Owner, Slices Of Life
Joakim Haugland, Owner, Small Town Supersound
Eva Karman Reinhold, CEO, Owner, Smilodon/Karman Innovative Consulting; SOM – Svenska Oberoende Musikproducenter
Alejandro Varela, Owner & Chair, S-Music Records
Maurice Summen, Owner, Staatsakt / Fun in the Church
Fredrik Holmgren, CEO, StarTracks AB
Margit Sarholz, Musician, Sternschnuppe Verlag GbR
Werner Meier, Musician, Sternschnuppe Verlag GbR
Kees van Weijen, President, STOMP – Stichting Onafhankelijke Muziekproducenten
Gugai MacNamara, CEO, Strange Brew
Jonathan Poneman, Co-Founder, Sub Pop
Megan Jasper, CEO, Sub Pop
Tony Kiewel, Co-President, Sub Pop
Bo Magnusson, co-owner, Subspace Communications AB
Julian Scheufler, Producer, Südpark Studio München
David Dickenson, Founder, Suicide Squeeze Records
Wolfgang Koch, Owner, syborgmusic
Volker Sonntag, CEO, TAG-7
Tue Kjerstein, Partner and co-managing Director, Tambourhinoceros
Kristoffer Rom, Partner and co-managing Director, Tambourhinoceros; DUP – Danske Uafhængige Pladeselskaber
Detlef Engelhard, CEO, Termidor Musikverlag & Timba Records GmbH&Co.KG
Jakob Sørensen, CEO and Founding Partner, The Bank
Tony Morley, Managing Director, The Leaf Label Ltd
Ken Shipley, President, The Numero Group
Rob Sevier, CEO, The Numero Group
Mauro Farina, Founder, The Saifam Group
Gerald Oppermann, Founder – Owner, Timezone GbR
Teddy Maier, Founder, Tonzoo
Tweety Gonzalez, Owner & Chair, Twittin records
Sonia Duran, General Manager, UFI – Unión Fonográfica Independiente
Ari Stern, Founder, Underwater Peoples / Stern Records
Ina Schulz, Head of Label, Unique Musikverlag GmbH
Guilhem Cottet, Director-General, UPFI – Union des producteurs phonographiques français indépendants
Christoph Dohr, Owner, verlag dohr köln
Matthias Möbius, Owner, viamas gmbh
Alexander Hirschenhauser, Board Member, VTMÖ – Verband unabhängiger Tonträgerunternehmen, Musikverlage und MusikproduzentInnen Österreich
Jörg Heidemann, Managing Director, VUT – Verband unabhängiger Musikunternehmer*innen
Stephan Bourdoiseau, President, Wagram Music
Kevin Fleming, Managing Director, Warp Records
Brian Sampson, Owner, Western Vinyl
Doug Warner, Owner, Wharf Cat Records
Noemí Planas, CEO, WIN – Worldwide Independent Network
Jared Jones, Owner, Winspear
Ben Beardsworth, Managing Director, XL Recordings
Caius Pawson, Founder, Young
Tobba Andersson, Owner, Zorch Production

References

¹ Omdia 2024 Music Market Shares data – Europe market shares are based on the seven European country shares (UK, Germany, France, Italy, Spain, Netherlands, and Sweden) and the trade revenue results for each country. Collectively these seven countries account for around 80% of European trade sales.
² IFPI, Music in the EU 2024
³ Omdia 2024 Music Market Shares data by revenue – Europe market shares are based on the seven European country shares (UK, Germany, France, Italy, Spain, Netherlands, and Sweden) and the trade revenue results for each country. Collectively these seven countries account for around 80% of European trade sales.

About IMPALA

IMPALA was established in 2000 and now represents over 6000 independent music companies in Europe. 99% of Europe’s music companies are small, micro and medium businesses and self-releasing artists. Known as the independents, they are world leaders in terms of innovation and discovering new music and artists – they produce more than 80% of all new releases and account for 80% of the sector’s jobs. IMPALA’s mission is to grow the independent music sector sustainably, return more value to artists, promote diversity and entrepreneurship, improve political access, inspire change, and increase access to finance. IMPALA works on a range of key issues for its members and started a new co-funded work programme as an EU cultural network in 2025. IMPALA runs various award schemes and has a programme aimed at businesses who want to develop a strategic relationship with the European independent sector – Friends of IMPALA