1 Written Brief For the Public Record Standing Committee on Transport and Communications September 15, 2022 By Nathan Wiszniak, Head of Artist and Label Partnerships in Canada at Spotify Regan Smith Head of Public Policy, Government Affairs1 Spotify is the most popular audio streaming service in Canada and around the world. We connect listeners to the audio they love, and connect creators to the fans who find meaning in their art and sustain their career. We thank the Committee for its commitment to hearing a diversity of perspectives on Bill C-11.

We share our viewpoint in the hope of bringing a concrete understanding of how our technology works in the cultural space as well as areas where the draft legislation should be amended to facilitate implementation activities by both the Canadian Radio-television and Telecommunications Commission (CRTC) and good faith partners looking to comply. Spotify is committed to Canada’s unique and diverse culture. And that commitment yields real results.

With over 11 million monthly users in Canada, and 433 million worldwide, Spotify is developing new Canadian artists and podcasters and helping them build new audiences in and out of Canada. In contrast to the captive airwaves of traditional radio, interactive streaming has made space for new talent from francophone, Indigenous, and other Canadian creators at the 1 Nathan Wiszniak brings over 20 years of music marketing and programming experience to the Spotify Canada team.

His knowledge of the Canadian marketplace can be attributed to his positions at Sony Music in Retail and Artist Marketing and at Universal Canada where he was responsible for the marketing, acquisition and distribution for a diverse roster of independent labels and artists. His role at Spotify Canada over the past 7 years as Head of Artist And Label Partnerships encompasses the day to day relationships with label s, artists, songwriters, management and organizations within the Canadian music industry, and leads the local strategy in building an ecosystem to promote and export Canadian creators at home and abroad.

Regan Smith has over 20 years of experience navigating legal and policy issues at the intersection of media and technology. She previously served as General Counsel and Associate Register of Copyrights in the United States Copyright Office, where she successfully led a broad portfolio of regulatory, litig ation and policy proceedings, including the most significant update to music regulations in four decades. At Spotify, she works cross functionally to analyze and develop policy positions on a broad range of proposed laws and regulations globally that may affect the company’s business operations.

2 heart of the Bill’s objectives, who have been either marginalized or ignored by traditional commercial broadcasters. Consider the data: ● In a given week, Spotify listeners in Canada discover over 83 times more Canadian music than Canadian songs played on broadcast radio. ● Spotify pays roughly two-thirds of music revenue to rightsholders, which is 8.5 times as much as radio, and 30 times as much as broadcasters of music-videos. That’s over CAD 8.9 billion (USD 7 billion) globally in 2021. ● Eight billion streams of Canadian music or podcasts are exported every month on Spotify.

The top 9 international markets for Canadian artists provide 7.2 streams of Canadian content for every one in Canada. ● Streaming is driving record revenues for our record label and music publishing partners, now representing 77.9% of the market for recorded music in Canada. Spotify’s efforts are unlocking success for Canadian artists in many genres and at many stages of their career – from global superstars like The Weeknd, to award winning artists like Charlotte Cardin, to newcomers like Jessia.

Artists that represent Canada’s special diversity – from breakout Québécois rappers to Canadian Punjabi musicians experiencing huge success at home and in India – are being elevated and tapping into new audiences not available on radio. We are proud of these efforts and believe Spotify can be a model for how an online undertaking can responsibly contribute to Canada’s creative ecosystem. We want to continue to deepen our successful investments to nurture Canadian culture.

However, while we support the ultimate objectives of Bill C-11, we are concerned that transposing rules based on the radio model to the streaming environment could be a barrier, not an incentive, to achieving these goals. Without adequately taking into account the unique aspects of audio streaming, regulation could disrupt incentives or hamper efforts that are already working to elevate Canadian creators, unintentionally suppressing opportunities for Canadian creators and culture online.

We are gratified that the Government is listening to these concerns, and appreciate that it may provide policy direction to steer regulation. However, the underlying framework of Bill C-11 is expansive and offers the CRTC little in the way of guidance regarding how to create groundbreaking, first in the world regulation for the audio streaming ecosystem.

To ensure that the framework preserves what is working and avoids unintended consequences for Canadian creators, we believe additional adjustments are necessary before moving forward, and offer four specific, practical suggestions designed to further the Bill’s objectives: ● The legislation should provide specific factors reflecting familiarity with audio services that the CRTC must consider before regulating.

Such factors, which could be established by the Governor-in-Council, should include the financial contributions and other support that a service is already providing to Canadian creators, the amount and range of Canadian content already available from the online undertaking, and direct and indirect efforts to help Canadian creators reach domestic and international audiences. Expectations for economic contributions must also take into account existing

3 contributions to support Canadian culture, including royalty payments. ● Requirements to showcase Canadian content must not override user preferences, which is especially important for personalized recommendations. Because streaming is based on listener choice, if compelled to listen to content that does not appeal, they will skip tracks, which is a bad outcome for creators, fans, and our business model. ● The rules defining Canadian Content must be updated as a first step.

Services do not receive sufficient metadata to apply these rules to our list of tracks, and many songs our society colloquially understands as “Canadian” across all tiers are unlikely to qualify.

Even after updating the rules, given known challenges related to accessing accurate and comprehensive metadata in the music industry, services should be able to use good faith, commercially reasonable efforts to identify Canadian Content, in light of information made available to them by commercial partners and artists. ● With the market still evolving, the CRTC should be given sufficient time to follow the evidence before making regulatory decisions.

Our following testimony focuses on three areas: ● A description of Spotify’s streaming services and our commitment to Canadian creators; ● Why personalized audio streaming is different, and why rules should take into account the unique features of this business model; and ● Areas we feel call for amendment to the legislation or accompanying guidance. Spotify invests in the future of audio and the creators behind it. When we launched in 2008, the music industry was in crisis. A model of distribution based on radio play and record stores was no longer sustainable.

Rampant online piracy of copyrighted works was killing the market for paid music, and destroying the careers of Canadian artists. Our model showed a new, better way forward. Our platform offered consumers a better choice than piracy, and got people to pay for music again. Spotify has become the platform of choice for consumers to find what they love and for artists and podcasters to share their work. We offer a comprehensive catalog of music and audio to listeners, through paid subscription or free, ad-supported tiers.

Users can discover, manage, and share over 80 million tracks, including 4 million podcast titles. Music is created by third parties and licensed from creators via recording companies, distributors, and publishers. Many podcasts are also created by third parties and redistributed by Spotify, while others are developed in-house. Our personalized and relevant playlists are why users subscribe, and our editorial and technical teams are best in class.

From playlists on a user’s screen “shelves” to the tracks themselves, our recommendations take into account many factors, including what the user is listening to and when, which songs they are adding to playlists, the listening habits of people who have similar tastes, and much more. About two-thirds of every dollar Spotify makes from music is paid to creators – artists, performers, songwriters, producers. Since our founding, we have paid over CAD 38 billion (USD 30 billion) to rightsholders around the world, including over CAD 8.9 billion (USD 7 billion) in

4 2021 – the largest annual sum ever paid by one retailer to the music industry and up from CAD 6.3 billion (USD 5 billion) in 2020. And Spotify creates opportunities that local broadcasters cannot match. We operate in over 180 countries, with a total addressable market of over 200 million French-language users. Eight billion streams of Canadian music or podcasts are exported every month. Put together, the top 9 international markets for Canadian artists provide 7.2 streams of Canadian content for every one in Canada.

Focus on Canadian creators Spotify launched in Canada in 2014 with a commitment to growing the stage for its artists. Our local content team’s mission is to foster Canadian talent through playlisting, marketing campaigns, partnerships, and training that empowers artists, writers, and podcasters to organically grow their audience. Spotify has over 140 full time staff in Canada, including 17 persons based in Québec. Our homegrown approach is now best in class and is moving Canadian culture forward.

Our music teams contribute to the curation of over 90 playlists that spotlight Canadian artists across genres such as Rap québ, Mood Ring, Live Country, Café montréalais, Northern Bars, Les classiques francophones, and Canadian Weekend. Flagship playlists include: ● RADAR Canada showcases rising stars like Saya Gray and provides teams with tools and editorial support to help emerging artists find their audiences. Over 1,000 emerging Canadian artists have been included in the RADAR Canada playlist since 2020. ● New Music Friday Canada features an average of 50% Canadian content each week.

Its counterpart, Nouveautés de la semaine Canada, promotes 100% new francophone releases each week from Canadian and international artists. ● Du Québec spotlights Québec artists, culturally important new releases, and celebrations. ● Indigenous gives curatorial control to Indigenous artists like three-time Juno Award winner Susan Aglukark, with supporting video content for Indigenous storytelling and cultural awareness. On average, our Canadian team’s editorial playlists program a high rate of Canadian music, at 35.9% overall, while our local flagship playlists are focused on programming 100% Canadian content.

Editorial efforts are complemented by tailored on- and off-platform promotions. We were this year’s official playlist sponsor of Les Francos de Montréal, the world’s largest francophone music festival and official partner of Les Rendezvous-Pros des Francos which promotes music industry exchanges from all francophone countries. Social impact campaigns elevate voices from marginalized communities many listeners may not otherwise encounter, such as Caribbean Carnival, Asian Heritage Month, and Punjabi 101. Users can also explore content

5 hubs like Equal, Frequency, and Pride Canada to celebrate the expression of Canadian women, Black, and LGBTQ+ creators, among others. Our Spotify Singles program, which has generated 6.73 billion streams globally as of this month, plans at least 36 recordings by Canadian artists in 2022 alone. In May, we collaborated with JUNO winner Savannah Ré and Punjabi-Canadian artist Ikky Singh in July on his latest single. Sound recording rights for Spotify Singles are 100% owned by the artist and label.

The program is part of our wider creative support through studio partnerships in Toronto and Montréal, as well as a dedicated Toronto studio for the songwriter community to work and collaborate at no cost. Just as importantly, we empower creators directly with tools for success. Spotify for Artists provides creators with access to crucial data about their fans, what they like, the artist’s stream counts, in addition to control over their creative profile, avenues for merchandise and concert ticket sales, and the ability to pitch music for curated playlists.

Our songwriter counterpart, Notable, provides a central point to access information including Spotify Publishing Analytics, Songwriter Pages, and our Songwriters Hub. And Spotify is not just a music service–podcasters can create and distribute via our platform and to others through our Anchor service. We provide podcast audience insights and other support to create and promote engaging stories.

Spotify directly finances production of original podcasts through studios Gimlet Media, Parcast, and The Ringer, investing in diverse content that ranges from culture, politics, sports, and the arts, true crime, and documentary. These efforts are paying off Our unparalleled dedication to Canadian creators is paying off. Spotify has a Canadian audience of 11 million monthly users, capturing ears that aren’t tuned to radio. In 2014, streaming provided just 10% of Canadian music industry revenue. In 2021, according to IFPI data, streaming represented 77.9% of the market.

Streaming revenue continues to power the music industry, increasing 18% year over year in 2021 and outpacing growth in all other segments. It is no surprise that the rise of streaming brought massive global success to top Canadian artists like Drake, the Weeknd, and Justin Bieber, 3 of the top 10 most streamed artists around the world. But Spotify does not just amplify the largest stars. In just one week in May 2022, Spotify users in Canada listened to over 600,000 distinct Canadian tracks.

That’s over 83 times more individual tracks of Canadian music explored on Spotify compared to unique Canadian songs played on Canadian radio over the same time period. Spotify’s personalized, interactive model uplifts Canadian voices who would not be heard over traditional airwaves – or by younger fans who have moved on from broadcast radio. We don’t take a paint-by-numbers approach or employ quotas, but work to support an artist’s own strategy in ways that satisfy our listeners.

Consider the following case studies: ● After being featured on RADAR Canada in March 2022, independent pop artist Leith's audience increased by over 115%, with half of the growth occurring internationally.

6 The Canadian team then pushed Leith's success within Spotify, featuring her as the face of the RADAR global franchise. This May, Leith released her debut EP to an audience exponentially larger than prior to her RADAR involvement. Thanks to global editorial support, two-thirds of user streams were driven from curated Spotify playlists. ● Spotify has supported four-time Juno winner and Montréal native Charlotte Cardin from the inception of her music career.

Aligning with Charlotte and her independent record label's strategy in 2015, Spotify Canada localized consumption in Canada, and eventually increased export efforts to international territories where today, France, Turkey, and the US rank amongst her top territories. Charlotte's music now lives on over 100,000 user generated playlists around the world, and with over 255 million streams by fans globally, she is now able to tour globally. ● Spotify is a home for the cultural rise of Canadian francophone hip hop (Rap québ).

Through promotion of Spotify Canada’s Rap québ and Les Nouveaux Classiques playlists and above the line marketing campaigns, artists like Loud, Souldia and others have grown audiences and careers without the aid of any radio play. Today on Spotify, 7 out of the top 10 most streamed French Canadian artists are independent French Canadian rappers. Only two of those artists appear on French Canadian radio charts.

Spotify programmed playlists have accounted for over half (56%) of new listener exposure to the artist Souldia, for example, helping to fuel his organic rise. ● Spotify’s editorial playlists can open doors for emerging artists like Québec singer- songwriter Alicia Moffet. Sixty-two percent of users that discovered Alicia Moffet in the past year found her on a programmed playlist. In June 2019, 93% of New Music Friday Canada listeners who heard Moffet’s hit “Take Control” were discovering her for the first time.

Similarly, for her track “Lullaby,” of the 149k users who listened in the first week after release in early 2022, 57% of them heard it for the first time on a programmed playlist. ● Spotify’s celebrations of cultural moments like Saint-Jean-Baptiste Day have driven listeners to old and new standards of Québécois music. In 2021, our Bonne St. Jean playlist marketing campaign drove incremental consumption amongst listeners in the province.

Songs from Canadian Francophone artists landed within our top 200 songs chart as a result of the investment in above the line marketing, on platform merchandising and playlist curation. The campaign drove a 17,000% increase in daily active users and 28% growth in followers to the playlist. Meanwhile, Spotify empowers professionals and users alike to create and share podcasts with global audiences. From professional productions like CANADALAND, Canadian True Crime, or Radio Canada’s Ça S’explique, to user uploaded podcasts hoping to reach friends and family, Spotify helps Canadian podcasters share their stories.

Our investments in original productions also elevate Canadian storytelling, such as Stolen: Surviving St. Michael’s, created by award-winning Canadian Cree journalist Connie Walker, bringing awareness to historical traumas of Indigenous communities.

7 Audio streaming is a user-led experience with uniquely comprehensive catalogs Audiocentric streaming is not broadcast radio, nor is it audiovisual streaming. It operates under a different business model and offers a different entertainment experience. We believe Spotify exemplifies behaviors that Bill C-11 aims to encourage, and want to continue to live these values. However, legislation without further attention to the specifics of audio streaming could create impediments to those aims.

First, streaming is interactive – every user is in control of what track they listen to, and the experience is highly personalized. Second, unlike audiovisual streamers like Netflix or Disney+, audiocentric services typically offer large, comprehensive repertoires. With over 80 million tracks, chances are Spotify already carries your favorite Canadian artist or composer. Our large repertoire coupled with a user-directed nature means that Spotify is built around discovery of new music and stories so that listeners keep returning to our service. It is one of our competitive differentiators.

Rather than push music according to a quota or one-size-fits-all manner, we tailor our efforts to drive discovery at the times users are most open to new music or podcasts. This strategy has made us the most popular audio streaming service in Canada and introduced countless artists. We want to ensure C-11 lets us continue to do what works. As background, most content consumed on Spotify – over 70% of all streams – is the result of “active streams,” meaning content chosen by users through searches, saves, and personal playlists.

At other times, though, users are open to discovery, whether through editorial playlists like New Music Friday Canada, personalized Songs to Sing in the Shower suggestions, or perhaps by enabling an autoplay experience. Our educational site, Made to be Found, walks through various types of discovery, and is designed to empower artists to find their audiences. As relevant to Bill C-11, we find that our editorial programming efforts are overweight drivers of artist discovery, including our flagship Canadian music playlists. Take the case of British Columbia pop artist Jessia.

After an initial viral wave in January 2021, inclusion of her single “I’m Not Pretty” on a number of editorial playlists led to Jessia’s sustained success. Despite ebbing of that early organic wave, editorial playlists accounted for 40% of Jessia streams through April of 2021 - the largest single source of streams. This has driven continued discovery and exposure to larger audiences, which still reach an average of 80,000 new users per week. At the same time, our personalized recommendations of Canadian music to users in Canada are closely proportionate to the amount of Canadian tracks users self-select.

This is by design. Algorithmic recommendations, such as our “Discover Weekly” playlist, strongly reflect user tastes. We always try to recommend content users want to hear at that moment. If not, a user will skip a song and switch to one of the 80 million other tracks available, leave a playlist, or end their listening experience altogether. Over time, repeated unsuccessful recommendations would degrade the Spotify experience and create negative feedback data for those songs as well. This does not mean our recommendations are an echo chamber.

On the contrary, through respecting the user-led nature of the experience, over one-third of new artist discoveries on Spotify now happen through personalized recommendations.

8 Taken together, our experience teaches us that efforts to promote Canadian content must not override user preferences. While we happily dedicate editorial playlists to Canadian content, asking services to bias recommendations away from listener preferences would strike at the core user trust companies like Spotify have painstakingly built with our customers. Without the captive audiences of traditional radio, repeated recommendations that misfire can actually result in less overall consumption of Canadian content. This risk has already been recognized by the Canadian government.

According to the 2020 report Attitudes and Opinions Toward Commercial Radio in Canada prepared by Ipsos Public Affairs for the CRTC, a substantial majority of Canadians feel that any future regulations on streaming music services should not interfere with consumers’ ability to choose the content they want. Ironically, transposing traditional Canadian content rules designed for broadcast radio to streaming would result in less, not more, Canadian content (to avoid promoting content that cannot be proven strictly to be “Canadian”).

This could homogenize the listening experience and disadvantage emerging or underrepresented artists. Fractured or incomplete metadata and artist collaborations make it impossible for streamers to apply the current

definitions of a Canadian song to their full libraries. A modern song may have dozens of songwriters, lyricists, and performers behind it, and be recorded in pieces in different locations. One report estimated that on average, it took 5.34 people to write the 100 biggest hits of 2018, an amount that was rising by “half to a whole songwriter every year.” In many cases, the full list of contributors to a song or a podcast is not made available to Spotify, and data provided by a sound recording distributor does not generally include nationality identifiers or data relating to musical compositions.

Given these known industry dynamics, Spotify presently employs a data-sensitive approach that considers tracks “Canadian” by combining a few inputs indicative of artist origin, such as self- identification through Spotify For Artists or metadata feeds transmitted by Gracenote, a multinational entertainment data company, as well as our editorial expertise. If required to limit our understanding of Canadian music to the current radio definition, many songs by Canadian artists across all tiers are unlikely to qualify, including Spotify Canada charting songs by Justin Bieber, Tate McRae, and Faouzia.

For emergent mediums like podcasting, regulatory

definitions for Canadian Content do not exist. The user-uploaded nature of many podcasts compounds the metadata challenges we anticipate with licensed music tracks. The economic incentives must work Any expenditure expectations must also take into account the economic differences in audio streaming compared to other sectors. In paying roughly two-thirds of music revenue in licensing fees, Spotify is already paying 8.5 times as much as radio, and 30 times as much as broadcasters of music-videos.

Currently, basic Canadian Content Development (CCD) contributions for radio are calculated as a percentage of broadcaster revenues, without reference to costs. It does not make sense to apply the same revenue-based formula to streaming services, which already pass through an overwhelming portion of revenue over to

9 rightsholders. In radio, the maximum amount payable to creators for non low-use, non-French or French language stations in Canada is approximately 8% of gross annual income (1.7% for reproduction rights and 6.2% for public performance). And the use of music videos by cable or satellite broadcasters requires an even smaller payment of 1.9% of the programming services’ revenue. Audio streaming is still nascent and growing. The licensing framework for music and other audio is notoriously complex, and margin pressure means this sector has yet to consistently demonstrate sustainable profits.

Without certainty that our royalty payments, and our extensive direct and indirect efforts to promote Canadian creators globally will be properly considered, Spotify — like any business faced with new costs — may need to make tough choices about the investments we can make in the future. Finally, any changes in law or regulation should consider that pure play digital service providers like Spotify would be affected differently than music streaming services provided by large vertically-integrated companies, such as Google, Apple, or Amazon.

Larger companies are able to underwrite their music streaming business through other activities,

whereas Spotify must compete on user experience to be financially viable. In advancing their stated goal of a “tech neutral” framework, we urge C-11 supporters to consider these dynamics. Changes that disadvantage pure play providers would not only reduce competition and consumer choice, but ultimately also lead to reduced overall revenue for creators. In light of already challenging margins, it is important to recognize the customized investments in Canadian artists, songwriters, and podcasters that are already powering new careers – both royalty payments and artist campaigns like the examples in this testimony.

Recommendations Spotify is committed to Canadian creators, and growing audiences and revenue for emerging or historically less represented artists. While we support the Bill’s overarching objectives, more guidance and clarity are needed to preserve what is already working, and ensure the Government’s intent is successfully implemented. Though other jurisdictions have explored approaches to promote local audiovisual content online, Bill C-11 would make Canada the first in the world to regulate audio streaming in this way.

Given the lack of international models and best practices, it is incumbent on the Government to provide more guidance to CRTC that would facilitate its task. To this end, we urge policymakers to ensure C-11 adequately addresses the audiocentric ecosystem by considering changes in several areas. 1. Specific guidance for regulating online undertakings, including contribution expectations. We commend the Government for contemplating a flexible approach that permits the CRTC to make orders affecting individual entities on a case-by-case basis.

But within the context of a flexible framework, the legislation would benefit from guidance specific to audiocentric streaming, which has unique economics, content ownership, and consumer

10 expectations. While in some places, the legislation is quite specific with respect to traditional radio carriage or audiovisual production obligations, the bill speaks little to audio streaming in particular. We urge the Government to include such guidance in the legislation itself in order to facilitate effective implementation and compliance planning, and provide greater certainty for continued investments in the audio ecosystem. More guidance would also ease future processes before the CRTC.

The legislation will confer new powers in a highly technical area where the CRTC has not yet developed a body of experience. As it assumes new mandates, Parliament should provide the CRTC clarity to discourage unnecessary rulemaking and avoid a disruptive impact on the audio ecosystem. There are three areas where further guidance is especially relevant. First, Spotify recommends the Governor-in-Council be given the power to establish factors that the CRTC must consider when deciding whether to impose regulations on an online undertaking.

The factors should include: ● the benefits and supports that the undertaking is already providing to Canadian creators including financial contributions; ● amount and range of Canadian content already available from the online undertaking; ● access of Canadian creators to opportunities to distribute and promote their content; and ● direct and indirect efforts to help Canadian creators reach domestic and international audiences, including on- and off-platform marketing, playlist promotion, data analytic tools, and artistic development.

Second, it is specifically important that any economic contribution rules are proportionate, and take into account contributions already made to support Canadian culture, including royalty payments. Without this certainty, we are concerned that added financial obligations will displace ongoing efforts to support the sector, including high-impact in-kind support which is especially valuable for independent and early-stage artists.

Third, proportionality requirements should be limited to programming over which an online undertaking has direct control and for which the undertaking can reasonably and reliably identify the nationality of the creator. Because consumers expect access to comprehensive audio libraries, requirements should be aimed at services’ playlistling, rather than applying a user consumption metric. 2. Discoverability and personalization. We urge an approach to discoverability which respects expressed user preferences navigating comprehensive libraries.

We are concerned the legislation could otherwise negatively impact the listener experience, and in turn, creators. We recognize that C-11 would prohibit the CRTC from requiring the use of specific algorithms or source code and appreciate the Government’s reassurances that regulating algorithms is not its intent. Realistically, however, any order applying discovery obligations or requiring the prioritization of specific content in

11 recommendations will likely require changes to algorithms. To better effectuate that intent, we recommend an amendment to prohibit any order that would impair or interfere with the operation of an algorithm or source code where content is provided based on user preferences, so long as it does not unduly restrict the showcasing or discovery of Canadian programs. 3. Definition of Canadian Content. We commend the Government for recognizing the need to modernize rules governing Canadian Content, and offer specific suggestions based on our expertise with digital music distribution at scale.

We suggest two changes before applying Canadian Content obligations to platforms of 80+ million tracks to ensure songs we colloquially recognize as “Canadian” can continue to be playlisted and promoted, and avoid recreating the repetitive and more limited “artist burn” experience of radio play: ○ First, the CRTC must modernize the definition of Canadian Content before new obligations attach to online platforms. ○ Second, future provenance obligations on services should be flexible and intuitive in light of global music industry metadata challenges.

We recommend letting platforms use good faith, commercially reasonable efforts with respect to the identification or promotion of local content, in light of information provided to it through designated channels by partners, creators, or the government. 4. Timelines, no presumption of regulation. Finally, we encourage Parliament to ensure that the legislation provides sufficient time and flexibility for the new framework to be responsibly implemented. Bill C-11 represents a major overhaul of the Broadcasting Act, and one that would authorize regulation of online services in novel and untested ways.

Instituting regulatory obligations that achieve these goals without disrupting existing successes will require a careful and nuanced approach to implementation. The CRTC may require additional time to work out all of the points necessary. In some cases, the better course may be to refrain from promulgating orders until markets mature or to allow the continuation of positive trends. Conclusion Spotify is committed to working with policymakers to ensure a strong legislative framework and successful implementation of this Bill.

We offer a practitioner's perspective, and want to lead the charge in elevating Canadian voices. We appreciate the focus on updating the Broadcasting Act, but urge the Committee to take the time to make the needed adjustments to make sure the changes are right. We thank the Committee for its attention to this important topic and openness to hearing a diversity of views.