Madrid, 15^th January 2026

With just a few weeks until the European Commission’s final decision on the Universal/Downtown deal, WIN wrote to Commissioner Valdis Dombrovskis to warn that the proposed remedies will not mitigate the grave risk that the merger poses to fair competition in the music market, and reiterate that the deal must be blocked outright.

Commissioner Valdis Dombrovskis
European Commission
Rue de la Loi / Wetstraat 200
1049 Brussels
Belgium

15 January 2026

Dear Mr. Dombrovskis,

For over a year, the global independent music community has repeatedly expressed concerns about the harmful consequences of Universal Music Group’s (UMG) proposed acquisition of Downtown Music Holdings. Given Downtown’s portfolio of essential and highly innovative businesses that power thousands of other independent companies, voices have been raised across markets about the risks to fair competition, market access, and cultural diversity. 

The European Commission (EC) acknowledged the sector’s concerns and launched an in-depth investigation into the transaction. It concluded that UMG could gain an “information advantage” from the commercially sensitive data stored on Downtown’s Curve platform, thereby harming their competition. UMG has since proposed remedies, which the EC has market tested. However, if confirmed, these remedies fall far short: the risks to the music market go far beyond Curve and data. 

Our European homologue IMPALA addressed these issues today at the first main trade conference of the year in the Netherlands. We echo their concerns, as this issue affects more than one continent. We are writing on behalf of the 37 trade association members of the WIN network spanning 43 territories and five continents, representing thousands of independent music businesses worldwide. With just a few weeks until the EC’s final decision, they view Europe as a beacon of fair competition. 

If there are data concerns about Curve, the same should be said for the rest of Downtown’s portfolio. FUGA is a revealing example because it owns valuable data on what makes a record label successful, including operational, marketing, and streaming intelligence. This includes detailed monthly performance and release schedules, audience demographics, privileged information on relationships with streaming platforms and editors, and details on third-party deals.

Collectively, the Downtown group of companies contains critical, proprietary data that could enable UMG to develop investment and marketing strategies, outbid competitors, and strengthen its market position. This would severely endanger many independent businesses. 

But this is about more than just data; it is also about choice. The deal threatens another essential pillar of the music ecosystem: independent distribution. If allowed to proceed, the deal would leave over 1,000 FUGA clients and 2 million CD Baby musicians with an impossible choice: stay and become dependent on UMG, or leave and face the cost and complexity of switching distributors and losing key data. 

Meanwhile, the world’s largest music company is continuing its global acquisition spree after restrictions placed on it by the EC following the acquisition of EMI were lifted in 2022. It has taken over companies in the Netherlands, Belgium, Spain, the United Kingdom, Japan, the United States, Thailand, Nigeria, China, the United Arab Emirates… Just days into 2026, UMG secured worldwide distribution rights for the Indian entertainment giant Excel, valued at over €220 million. 

This pattern shows UMG’s intent to capture value, increase control, and outperform their competitors by acquiring key independent music companies. As consolidation grows, their competitors find fewer options available. 

Control of distribution is not just about revenue and market share; it also gives UMG leverage to dictate terms with streaming platforms. We have already seen this with the recent changes to royalty payments that “demonetise” millions of songs by emerging artists. This reallocation of income is creating a reverse Robin Hood effect with a two-tier music market that funnels revenue to major players.  

A new study in the Balkans revealed that 65% of independent record labels reported significant revenue losses since the new thresholds were introduced. Besides monetary harm, these remuneration policies also hinder cultural diversity and geographical equality. And this trend may be just beginning, as UMG’s CEO Lucian Grainge just announced an extension of the Streaming 2.0 strategy to other platforms. 

This is a crucial moment. The investment-based model of independent music businesses brings significant economic and career-building value to artists, but it is currently at risk.  

The European Commission has a track record of leadership in competition cases, and its decision to open an investigation on this acquisition is proof of that. The remedies proposed by UMG will not mitigate the grave risk that this transaction poses to fair competition. The world expects Europe to logically extend its objections to the other companies of the Downtown group, in line with the harm already identified by the EC, and to oppose the full transaction. 

This is the only way to ensure that the tens of thousands of independent music companies and entrepreneurs who support the careers of millions of artists, pioneering talent, emerging sounds, and diverse musical genres and cultural expressions every day, have an equal opportunity to compete. 

This case is also important for the future, as we expect consolidation attempts and threats to competition to continue to increase, and not just in the music industry.  

Our message remains clear: some situations call for more than just remedies; they call for an outright block. 

Sincerely,

Noemí Planas, Worldwide Independent Network (WIN) CEO
Mark Kitcatt, Everlasting Records/Popstock Distribuciones (Spain) – WIN Chair
Cecilia Crespo, Asociación de sellos independientes de Argentina (ASIAr, Argentina) – WIN Vice-Chair
Marty Ro, Record Label Industry Association Korea (LIAK, South Korea) – WIN Vice-Chair

About WIN
The Worldwide Independent Network connects and develops the global independent music community. WIN brings together trade associations representing thousands of independent music businesses around the world. WIN acts as a global coordination and support network for the independent sector, focusing on its long-term development and sustainability. WIN promotes a diverse and vibrant ecosystem with full market access and equal opportunities for all independents, through transparency, innovation and cooperation.

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