London and Brussels 16 June 2025

Renowned economist and former regulator, as well as musician and independent music label co-founder, Professor Amelia Fletcher of the University of East Anglia, has sent a letter to the Vice President of the European Commission Teresa Ribera urging her to conduct an in-depth investigation into the proposed acquisition.

Professor Fletcher who served as chief economist of the UK competition authority and independent director of the CMA, says the acquisition represents “another step in UMG’s broader strategy of undermining the vitality and viability of the independent music sector” and that it is “vital that this anti-competitive process is stopped”.

She raises a number of issues, noting that the acquisition “will further strengthen UMG’s already significant negotiating power with digital service providers”, and that there is already a track record of UMG doing this. This follows a “pattern of acquisitions” which “both reduces the competitive constraint UMG faces from independents and also enables it to extract an ever-greater share of all digital revenues”.

She urges the Commission to “consider not just UMG’s market share by revenue, but its “control share”. She also notes that the merger would give UMG access to “critical commercial data” from Downtown’s platforms, giving them unfair insight and opportunity to target artists and songwriters, saying “this mirrors the recent case in which DG Competition took action against Amazon for using marketplace data to benefit its own operations as a supplier.”

Professor Fletcher raises that this combined effect means that it will make it much harder for new artists and emerging genres to be supported.

Fletcher’s letter follows the EC’s confirmation last month that it will be looking into UMG/Downtown because “…the transaction threatens to significantly affect competition in certain markets of the music value chain…” in many countries across Europe. The EC’s investigation will start as soon as the parties to the transaction supply all their data to complete their notification, which is expected shortly. After an initial assessment, the EC will have to decide whether to open an in-depth investigation.

The concerns echo issues raised in a new report released earlier this week “Combating the Emergence of a Two-Tier Music Streaming Market” where industry experts Dan Fowler and Katherine Basset identify “…a widening gulf between large rightsholders and independent actors, driven by market consolidation, opaque platform policies, and emerging monetisation practices that increasingly favour scale over diversity”.  

Helen Smith IMPALA Executive Chair commented: “Fletcher’s expertise is outstanding and her experience as an artist and independent label, as well as an economist and regulator, makes her testimony particularly compelling. With concerns about the deal growing within European institutions, including a recent parliamentary question submitted by Aurore Lalucq, Chair of the Parliament’s Economic Affairs Committee, it’s important that a full detailed investigation is launched after phase one. We look forward to working with the EC on this.”

Professor Fletcher’s full letter can be accessed here. As Fletcher notes, she wrote about Spotify’s payment thresholds in an open letter to Daniel Ek in 2023.