DIMA Remarks Before CRTC: Audio Policy Consultation and Discoverability

Opening Remarks: Graham Davies

CRTC 2025-52

Chair, Commissioners, thank you for the opportunity to appear today. It is a privilege to speak with you about music discovery in Canada and how we can build on the success that’s already here. These hearings matter because they will impact how artists are found, how fans connect with music, and how Canada continues to thrive in a global music economy in the future.

My name is Graham Davies. I am President and CEO of the Digital Media Association. DIMA represents the world’s leading audio streaming services, including Amazon, Apple Music, Spotify, and YouTube. Our members have played a central role in transforming the music market in Canada for the better, and at a critical time.

Two decades ago, most online music consumption came through piracy. By building a whole new ecosystem that provides legal access to the world’s music at your fingertips, our members have helped transform piracy into prosperity. Today, Canada stands as the eighth largest recorded music market in the world – this is a tremendous success story, and we are proud of the role that DIMA’s members have played. Streaming now generates the vast majority of Canadian recorded music revenues, paying more than half a billion dollars to rights holders last year.

At a time when Canadians are struggling with the cost of living, music streaming remains one of the best values they get for their money. For an affordable price, listeners get access to the music they want to hear, when they want to hear it. And rights holders and the artists they represent see year over year revenue growth.

Seventy percent of streaming service revenues flow to the rights holders, which is the highest contribution of any music business model. Affordability, scale, and sustainability go hand in hand here. Streaming delivers a win for consumers and a win for artists.

And streaming has also helped transform the music industry for the better. Streaming has not just opened doors; it has removed barriers. An artist in Bedford or Burnaby can now reach listeners across the country and around the world. Success no longer depends on knowing a radio programmer. Streaming gives all music creators access to the global marketplace, not to mention the array of powerful tools for analytics and promotion that our members provide. For the first time, an artist anywhere in Canada can find an audience anywhere in the world. Consumers, meanwhile, enjoy unprecedented access to music across genres, languages, and cultures.

This is one of the most successful stories in the history of Canadian music. Two thirds of Canadians use music streaming services, and among those under 30 the figure rises above ninety percent. More than eighty percent of users say they’re satisfied with their service. These are habits built on legal, licensed music, and they’ve driven growth in royalties that flow back to artists and rights holders. That shift is cultural and economic, and it’s built on consumer choice and private sector innovation.

A first principle for today’s discussion must be to recognize how streaming is different from other forms of music listening. Streaming is not radio. It doesn’t operate on scarce airwaves or fixed programming slots. It offers more than one hundred million tracks on demand, with each individual user able to customize and tailor their experience. Trying to apply radio era rules to this interactive world will not work. It risks undermining the very outcomes the Commission is trying to encourage.

Quotas designed for a one-to-many broadcast environment are incompatible with the reality of a one-to-one streaming environment where every home page is personalized and discovery is powered by a blend of editorial curation, algorithms, search, social media, and an artist’s own marketing.

And the concept of Canadian content was devised to serve radio quotas. It wasn’t designed for a global online market with unlimited shelf space. If CanCon is lifted from radio and dropped into the digital environment, it will fail because it mismatches intent and reality. To begin, the Commission should recognize that there are a variety of aspects that could make a song Canadian, whether a Canadian performer, producer or one of the songwriters is Canadian.

For example, Michael Bublé’s classic recordings of iconic Christmas songs may not even qualify under MAPL rules, even though he is himself Canadian. That’s a policy problem, not a market one.

There’s another reason local quotas don’t translate to streaming: the operational reality of digital supply chains. Streaming services don’t receive the metadata that would be necessary to identify a song as Canadian. There’s no field for nationality. And if there was, whose role would it be to populate this data? The process of music production in the modern era is collaborative and global. A Canadian singer might work with a British songwriter and an American producer, and release through a European label.

To the extent that the Commission will establish a prescriptive definition, without standardized industry metadata, it will be impossible for services to certify what counts as Canadian across catalogs. Any definition must be developed by the Canadian music industry itself, certified at source, and delivered through standardized metadata. That’s the only way it will work at scale. It must also be as flexible as possible, to ensure that Canadians are properly recognized for their work. An artist shouldn’t be penalized because they exercised their creative choice to work with a collaborator from another location.

DIMA’s members have already made significant investments in Canada without regulatory intervention or compulsion. The current levy proposal adds another cost layer which poses a threat to the ongoing investments that have enabled Canada’s music industry to thrive. The current base contribution has been described as modest -it is anything but in light of the way this business is structured. And some have suggested this current proceeding should drive the amount even higher. This would apply yet further pressure on already narrow operating margins of the streaming services.

If operating costs rise sharply, services face hard choices about whether to reduce investments in Canada or raise prices for consumers. In an affordability crisis, either path is harmful. If consumer prices rise due to government-imposed costs, fewer people subscribe, and more users may be driven back towards piracy. If investment shrinks, fewer resources can go to Canadian artists, partnerships, and programs. Either way, it’s artists or audiences who lose, and the Canadian music industry will feel those impacts.

It’s important to remember how we got here. Streaming didn’t succeed because of regulation. It succeeded because Canadians chose it. Because it works. It turned a piracy dominated market into one that is growing and sustainable. To interfere with that success without fully understanding how music streaming works puts the entire ecosystem at risk.

Some argue that while the global market is healthy, local segments may suffer. It’s true that in a democratized market, every artist competes for ears.

But the way to address that risk isn’t by forcing every consumer into a one size fits all experience. It’s by strengthening the inputs that actually drive success. Labels and publishers find, develop, and promote artists. Accurate, timely metadata enables royalties to be properly attributed and paid. Artists need education and outreach to use the tools that the services provide. And for the services part, they wish to continue to invest in editorial teams, partnerships with Canadian organizations, and programming that highlights Canadian and Indigenous music.

We also need to measure the right outcomes – this means measuring actual results – rather than measuring against arbitrary benchmarks. Traditional charts or relative market shares are not a good proxy for streaming success. Last year, a large proportion of artists who earned more than a million dollars from one of our members never appeared in the global top fifty. That’s the point.
Streaming distributes success more widely. It creates a robust middle. Communities form around every genre and every language. If we’re measuring health, look at the growth in listening to Canadian music, the absolute increase in consumption and audience size, the export performance of Canadian artists, the number of Canadians paying for legal music, and the flow of royalties. Those are the indicators that matter.

So, what does a constructive path forward look like? First, we must recognize the success of the system that exists. Don’t adopt rules that will make the product worse for consumers. If satisfaction drops because services are forced to replace the current listening options people rely on with mandatory categories, engagement will fall. Second, if there’s to be a definition of Canadian content for the online world, the music industry itself should organize to design and certify it. Third, we believe roundtables should be convened between services, rights holders, artists, and the Commission to build a shared understanding of how discovery actually works.
Fourth, it is important to take a data driven approach to measuring outcomes, from exports to language representation.

Finally, regarding the process itself, we encourage stakeholders to talk to one another directly, rather than risk talking past one another through filings. We have been concerned that in the course of the regulatory back-and-forth, opportunities have been missed to have meaningful industry dialogue, and attention has been diverted from the core, shared mission of supporting Canada’s music industry. To that end, we urge the CRTC to call for a stakeholder roundtable – providing an opportunity to establish a forum for open, collaborative discussion that will help build shared understanding and identify a more constructive path forward.

DIMA’s members are committed to being partners in achieving Canadian cultural policy goals. We want Canadian and Indigenous artists to reach larger audiences. We want more Canadians to legally access royalty generating music. We want a market that continues to grow artist royalties and careers. We’re ready to collaborate on measurement, metadata, and better outcomes.

What we ask is balance. Build a framework that supports discovery without undermining consumer choice or weakening investment. Build it on a realistic understanding of how streaming works, with responsibilities assigned to the right actors. And build it in a way that
keeps Canada attractive to global services at a moment when music faces unprecedented competition for consumers’ attention.

Canada can continue to be a global leader in digital music. That leadership will be stronger if policy fosters innovation, investment, and collaboration, rather than constraining them.

Thank you for your time. I look forward to your questions and to working together on the road ahead.