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Broadcasting - Staff Letter addressed to the Distribution List

Gatineau, 23 October 2025

Reference: 1011-NOC2025-0052

BY EMAIL

Distribution List

Subject: Requests for information regarding the proceeding initiated by The Path Forward – Supporting Canadian and Indigenous audio content, Broadcasting Notice of Consultation CRTC 2025-52, 20 February 2025

This letter sets out questions (also called requests for information or RFIs) related to the proceeding initiated by The Path Forward – Supporting Canadian and Indigenous audio content, Broadcasting Notice of Consultation 2025-52, 20 February 2025.

The RFIs set out in Attachment 1 are directed to specific parties and focus on the various issues set out in Broadcasting Notice of Consultation 2025-52 and on the record to date. These RFIs will allow the Commission to further develop the record in relation to comments it received during the hearing held from 18 September 2025 to 29 September 2025 and to address any gaps in the record collected to date. The distribution list is set out in Attachment 2.

In addition to questions directed to parties to this proceeding, the Commission is also directing questions to an entity that is not a party to the proceeding (non-party) as this information will facilitate the Commission’s consideration of the issues in NoC 2025-52. The non-party, Re:Sound, (identified with an asterisk in the distribution list set out in Attachment 2) is requested to respond to the specific questions directed to it.

Responses to the questions included in this letter are due by 10 November 2025. Please ensure that each question is repeated before your response. Reponses must be submitted using the secure service My CRTC Account (Partner Log In or GCKey) for filing the information. Those who do not have an account and are not submitting confidential information may use the Intervention web form for these RFIs.

All parties will have the opportunity to provide comments on the responses to these questions when they submit final written submissions. Please note that the Commission has announced in Broadcasting Notice of Consultation CRTC 2025-52-5 that final written submissions will be due on 28 November 2025.

Confidential Information

As set out in section 25.3 of the Broadcasting Act and Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, a person may designate certain information as confidential.

A party designating information as confidential must provide a detailed explanation of why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm likely to result from the disclosure would outweigh the public interest in disclosure.

Furthermore, a party designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Accessible formats for people with disabilities

The Commission requires regulated entities and encourages all parties to file submissions in accessible formats (for example, text-based file formats that enable text to be enlarged or modified or read by screen readers) for this proceeding.

To provide assistance in this regard, the Commission has posted on its website guidelines for preparing documents in accessible formats.

Where submitted documents have not been filed in accessible formats, parties may contact the Public Hearings group to request that Commission staff obtain those documents in accessible formats from the party who originally submitted the documents in question in an inaccessible format.

If you have any questions, please contact Jessica Morrison (Jessica.Morrison@crtc.gc.ca).

Sincerely,

(Original signed by)

Scott Shortliffe
Vice-President Broadcasting

Attachments (2)

  1. Requests for Information
  2. Distribution List

Attachment 1: Requests for Information

Section 1. Canadian audio content definitions and related metadata issues

ADISQ, Amazon, Apple Canada Inc., Association des professionnels de l’édition musicale, Music Canada, Panorama (formerly known as SOPROQ), SOCAN, Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs, Songwriters Association of Canada, Spotify

  1. Various interveners have submitted that metadata associated with digital music files frequently lacks key elements, including of the composer and lyricist, that would aid in identifying a track as Canadian content.

    1. What barriers exist that hinder accurate and thorough metadata?

    2. What barriers currently prevent International Standard Musical Work Codes (ISWCs) from being consistently linked to their corresponding International Standard Recording Codes (ISRCs) when music files are sent to streaming services?

      1. Subsequently, what prevents the relevant ISWCs and ISRCs from being sent, along with records regarding their streams, to rights management agencies?
Panorama (formerly known as SOPROQ)

  1. If the Commission were to add a First MakerFootnote 1 criterion, it would need to be traceable and easily identifiable, both for the Commission’s monitoring purposes and to minimize the administrative burden of identification for broadcasters. You mentioned that your practices for issuing ISRCs enable you to obtain all the necessary information to identify the First Maker of a recording and their nationality.

    1. Please describe your step-by-step process for issuing an ISRC. Does the process for issuing ISRCs differ internationally among other issuing bodies?

      1. Provide examples of cases in which ISRCs would not correctly identify the nationality of a First Maker, using screenshots, if possible.
      2. What specific information do you require to confirm the First Maker’s nationality?
      3. If a master sound recording is sold, would the ISRC still correctly identify the First Maker?

    2. Is complete and accurate information about Makers of sound recordings, including their name and nationality, publicly available?

      1. Please provide concrete examples (e.g. screenshots or official reports) of Canadian musical selections where the First Maker is clearly identified.
      2. Are there instances in which the name or nationality of a First Maker would be misidentified? Please explain.
ADISQ, Canadian Independent Music Association, Music Canada, Nettwerk Music Group Inc., Panorama (formerly known as SOPROQ), Re:Sound

  1. Pertaining to questions about the intellectual property of Canadian sound recordings:

    1. How is information about the current ownership of the copyright to a master sound recording shared and tracked?

    2. Is there a metadata standard that contains this information? If so, please explain how it is used.

      1. Is there a publicly available database that includes this information? If so, please demonstrate.
    3. How do you track the nationality of copyright owners?

    4. Is complete and accurate information about copyright owners, including their name and nationality, publicly available?

      1. Please provide concrete examples (e.g. screenshots or official reports) of Canadian musical selections where the copyright owner is clearly identified.
      2. Are there instances in which the name or nationality of a copyright owner would be misidentified? Please explain.
    5. Is there intellectual property other than copyright that you think is relevant to the protection of Canadian music industry creators?

  2. Keeping in mind that all criteria must be easily publicly identifiable and traceable:

    1. If you were to recommend that the Commission add a criterion for either the First Maker or the current copyright owner of the recording, which would you recommend, and why?
    2. How could both the Commission and broadcasters tell when a master sound recording has been sold?
ADISQ, Alliance nationale de l’industrie musicale, Artisti, GMMQ et UDA, Association des professionnels de l’édition musicale, Awesome Productions and Management, Canadian Independent Music Association, Canadian League of Composers, Helix Records, Indigenous Music Office, Makusham Musique, Music Canada, Nettwerk Music Group Inc., RAS Creative, Screen Composers Guild of Canada, Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs, Songwriters Association of Canada, Studio HAUSOFHAM

  1. The Commission has received several proposals to define an emerging artist, based on a variety of success-based metrics. However, as stated in the Notice of Consultation, the Commission’s intention is to implement a definition that does not require having to parse large amounts of information to determine whether an artist can be identified as emerging.

    1. What are the ways that the Commission could ensure support to emerging Canadian artists without having to rely on a definition?
    2. In your view, what is the most effective approach to support emerging artists through our policy? Should it be to support Canadian artists early in their careers; Canadian artists that have yet to achieve a certain level of success; Canadian artists that work with Canadian record labels or independently?
ADISQ, Alliance des radios communautaires du Canada, Alliance nationale de l’industrie musicale, Amazon, Apple Canada Inc., Artisti, GMMQ et UDA, Association des professionnels de l'édition musicale, Canadian Association of Aboriginal Broadcasters, Canadian Association of Broadcasters, Canadian Independent Music Association, Canadian League of Composers, CBC/Radio-Canada, Chaires IANF-CREAT, FACTOR, Fondation Musicaction, Indigenous Music Office, LATTICE-UQAM, Le Regroupement, Music Canada, National Campus and Community Radio Association, National Coalition of Canadian Ethnic Broadcasters, Ontario Association of Broadcasters, Ontario Library Association, Panorama (formerly known as SOPROQ), Screen Composers Guild of Canada, Sirius XM Canada Inc., SOCAN, Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs, Songwriters Association of Canada, Spotify, Stingray Group Inc.

  1. Several interveners have expressed interest in joining an industry-led working group focused on developing standards of practice for metadata for music in the Canadian music and broadcasting sectors.

    1. Do you foresee your organization joining such a group? If so, what would be your role?
    2. Who should take the responsibility for convening such a working group? Do you see the private sector taking the lead, or do you see the Commission playing a role? If so, why, and in what way?

Section 2. Discoverability of Canadian and Indigenous audio content

ACCORD, ADISQ, Alliance nationale de l’industrie musicale, Artisti, GMMQ et UDA, Association des professionnels de l’édition musicale, Canadian Independent Music Association, FACTOR, Makusham Musique, Music Canada, Nettwerk Music Group Inc., RAS Creative, Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs, Studio HAUSOFHAM

  1. In its written intervention, ACCORD distinguished “programmed” listening – in which an audio service has “programming control over, for example, editorial playlists, algorithmic playlists, editorial-algorithmic playlists, recommendations and auto-play” – from “active” listening, which is “when a user actively selects music either through direct search or saving to personal playlists.”

    1. Do these definitions sufficiently capture the different modes of listening on online streaming services? Please explain.

  2. The Association des professionnels de l’édition musicale said in their written submission that passive impressions are a key indicator for understanding how music is recommended on online audio service.

    1. Spotify calculates impressions by counting the number of times an item appears to a user on the Spotify appFootnote 2. Is this definition the industry standard for an “impression”?
    2. Are there specific metrics derived from aggregated impressions data could show whether the discoverability of Canadian, Francophone and Indigenous music has improved? Please explain.
    1. What works for improving the discoverability of Canadian content on streaming?
    2. Which features on streaming services drive listenership, engagement and fan creation to the greatest extent (e.g. editorial playlists, autoplay, algorithmic recommendation)? Provide specific examples and explain how the Commission could monitor these contributions and evaluate their efficacy, including in comparison to other contributions.
Amazon, Apple Canada Inc., Spotify

  1. In its written submission, CBC/Radio-Canada proposed that “online audio undertakings should be required to submit a plan detailing how they intend to ensure the promotion and discoverability of Canadian and Indigenous audio content.”

    1. What specific methods (including but not limited to: editorial playlists, recommendations and auto-play features like automatic playlist continuation or Spotify’s AI-DJ) would you include in a report to demonstrate the discoverability of Canadian, Francophone and Indigenous content on your service? Why those?
    2. Are there any existing reporting tools or dashboards that could be adapted to provide this information to the Commission?
  2. In Canadian dollars, list all annual costs associated with populating and promoting the Canadian- French language- and Indigenous-focused editorial programs on your service.

  3. Do you have any commercial arrangements that influence or prioritize specific artists, tracks or albums in:

    1. Search results on your service?

      1. If such arrangements exist, how are they implemented and disclosed?
      2. Can you provide examples of how these arrangements have affected content visibility, and whether they are measurable over time?

    2. Recommendations on your service?

      1. If such arrangements exist, how are they implemented and disclosed?
      2. Can you provide examples of how these arrangements have affected content visibility, and whether they are measurable over time?
  4. What percentage of streams on your service are derived from “programmed” listening, as described in Q6, versus “active” listening?
Canadian Starmaker Fund, FACTOR, Fondation Musicaction, Fonds Radiostar, Indigenous Music Office
    1. How do your funding programs specifically support the promotion or visibility of Canadian, Francophone and/or Indigenous music on streaming services?
    2. Do you offer specific funding streams to that end?
    3. If so, how much funding is available and what results are you seeing?
    4. If not, please explain if or how dedicated funding could help improve the promotion or discoverability of Canadian music on online services.

Section 3. A sustainable financial contribution framework supporting diverse Canadian content

Amazon, Apple Canada Inc., DIMA, Spotify
    1. Explain, in detail, what should be included in an annual report to show the marketing, promotion, and any other non-curatorial expenses you made in the preceding year to support Canadian music and musicians that cannot be claimed as part of your base contributions. The Commission can only recognize contributions that it can measure and track. Which investments in Canada should the Commission recognize?
    2. Would this information be valuable on its own, or would combining actual performance data such as user engagement (likes, shares, playlist adds) or passive impressions with these activities more effectively show contributions made to Canadian and Indigenous content, and why?
Canadian Association of Aboriginal Broadcasters, Gary Mandin, Indigenous Music Office, Makusham Musique
  1. As the Commission reviews the financial contributions framework, what should the funding priority be to ensure adequate support to Indigenous music and Indigenous representation in broadcasting?
Canadian Association of Aboriginal Broadcasters

  1. In your written submission, you proposed the creation of an Indigenous music distribution service.

    1. Who would work on this project, and in what capacity?
    2. Outline how creation of the service would work in phases, from set-up to implementation and maintenance, and to monitoring and reporting.
    3. How would each phase be financed?
    4. Should a portion of financial contributions be directed towards this initiative?
Indigenous Music Office

  1. In your written submission, you said your support to Indigenous music could include investment in “an Indigenous equivalent to DMDSFootnote 3.”

    1. Do you plan on being involved in the creation of an Indigenous music distribution service proposed by the Canadian Association of Aboriginal Broadcasters, and if so, is this separate from your work on an Indigenous music database?
    2. In what capacity would you be involved in this project?
    3. Should a portion of financial contributions be directed towards this initiative?
Arsenal Media inc, Bayshore Broadcasting, Bell Media Inc., Canadian Association of Aboriginal Broadcasters, Canadian Association of Broadcasters, Cogeco inc., pour et au nom de sa filiale Cogeco Média inc., Corus Entertainment Inc., Durham Radio Inc., Golden West Broadcasting Ltd., Leclerc Communication inc., Ontario Association of Broadcasters, Pattison Media, RNC MEDIA INC., Rogers Media Inc., Vista Radio Ltd.

  1. In its written submission, the Canadian Association of Broadcasters proposed aligning the contribution framework for commercial radio with the exemption levels used in the Broadcasting Fees RegulationsFootnote 4, with both a group threshold of $25 million in annual Canadian gross broadcasting revenues (ACGBRFootnote 5) and an individual station threshold of $2 million in ACGBR. Revenues below each threshold would be exempt from contribution requirements.

    1. If the above thresholds were adopted, what would an appropriate contribution level be, as a percentage of ACGBR?
    2. Other services (online, satellite and pay audio services) must contribute based on the total of their broadcasting revenues. Why should commercial radio only contribute based on revenues in excess of a certain threshold?
    3. What would the appropriate contribution level be if all audio revenues by groups earning greater than $25 million in ACGBR were eligible?
ACCORD, Canadian Association of Aboriginal Broadcasters, Canadian Association of Broadcasters, Canadian Starmaker Fund, DIMA, FACTOR, Fondation Musicaction, Fonds Radiostar, Indigenous Music Office, Le Regroupement, Sirius XM Canada Inc., Stingray Group Inc.

  1. During the hearing, a "play or pay" framework whereby audio services could choose between playing Canadian content over a certain baseline percentage or making higher financial contributions was discussed.

    1. What kind of exchange rate between financial contributions and Canadian content aired would be appropriate? For example, for every 1% increase or decrease from a hypothetical baseline percentage of Canadian content, what should be the corresponding percentage or dollar-value change in the required financial contribution?
Canadian Starmaker Fund, FACTOR, Fondation Musicaction, Fonds Radiostar, Indigenous Music Office

  1. To improve the discoverability of Canadian and Francophone music on online audio services, LATTICE-UQAM suggested that Canadian content development contributions earmarked for the creation of music recordings could be conditional on ensuring complete and accurate metadata associated with the recordings and creation of the underlying musical work, including personnel and commercial arrangements.

    1. Do you log or track any of the metadata associated with the recordings that you fund?
    2. What challenges or opportunities does this proposal present for you?

Section 4. News programming on audio services

Bell Media Inc., Byrnes Communications Inc., Canadian Association of Broadcasters, CBC/Radio-Canada, CJ Radio, Cogeco inc., pour et au nom de sa filiale Cogeco Média inc., Friends of Canadian Media, Le Regroupement, National Campus and Community Radio Association, Ontario Association of Broadcasters, Rogers Media Inc.
  1. Should the Commission expand the definition of audio news programmingFootnote 6 to be consistent with the audiovisual definitionFootnote 7 of news? Why or why not?
Arsenal Media inc, Bayshore Broadcasting, Bell Media Inc., Byrnes Communications Inc., C.J.S.D. incorporated / Northwest Broadcasting / North Superior Broadcasting, Canadian Association of Aboriginal Broadcasters, CJ Radio, Cogeco inc., pour et au nom de sa filiale Cogeco Média inc., Corus Entertainment Inc., Durham Radio Inc., Golden West Broadcasting Ltd., Leclerc Communication inc., Pattison Media, Prince Edward County Radio Corporation, RNC MEDIA INC., Rogers Media Inc., Torres Media, Vista Radio Ltd.
  1. What methods do you employ to assess and quantify the news requirements of the communities served by your stations?

Section 5. The future of audio

ADISQ, Artisti, GMMQ et UDA, Association des professionnels de l'édition musicale, Canadian League of Composers, Chaires IANF-CREAT, Panorama (formerly known as SOPROQ), SOCAN, Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs, Songwriters Association of Canada

  1. Many interveners expressed that content should not be considered Canadian if a human did not have creative control over its creation.

    1. Please list examples (up to five) of artificial intelligence (AI) tools used in music creation that maintain human creative control, and thus the ability for the creation to be copywritten.
    2. Are there circumstances in which someone could own the copyright of a work or recording, but a human did not have control over its creation? Please provide details if there are any examples.
ADISQ, Amazon, Apple Canada Inc., Artisti, GMMQ et UDA, Association des professionnels de l'édition musicale, Canadian Association of Aboriginal Broadcasters, Canadian Association of Broadcasters, Canadian Independent Music Association, Canadian League of Composers, CBC/Radio-Canada, Chaires IANF-CREAT, DIMA, Le Regroupement, National Campus and Community Radio Association, National Coalition of Canadian Ethnic Broadcasters, Ontario Association of Broadcasters, Panorama (formerly known as SOPROQ), SOCAN, Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs, Songwriters Association of Canada, Spotify

  1. Acknowledging that broadcasters may not always know if a particular selection has been generated by AI and that the Commission intends to minimize regulatory burden:

    1. What specific elements could a disclosure requirement include in order to ensure reasonable and effective transparency for listeners when AI-generated music is broadcast?
    2. What form could disclosure requirements take for different kinds of audio services?
Amazon, Apple Canada Inc., Spotify

  1. Creator groups have expressed fear that as the prevalence of AI-generated content increases, it will saturate your services, making it even more difficult for human-created Canadian content to be discovered.

    1. What steps do you take to ensure your recommendations and playlists don't favour AI-generated content over music from Canadian and Indigenous artists?
    2. Are there any further measures you could put in place? Please explain.
Alliance des radios communautaires du Canada, Arsenal Media inc, Bayshore Broadcasting, Bell Media Inc., Byrnes Communications Inc., C.J.S.D. incorporated / Northwest Broadcasting / North Superior Broadcasting, Canadian Association of Aboriginal Broadcasters, Canadian Association of Broadcasters, CBC/Radio-Canada, CJ Radio, Cogeco inc., pour et au nom de sa filiale Cogeco Média inc., Corus Entertainment Inc., Durham Radio Inc., Golden West Broadcasting Ltd., Le Regroupement, Leclerc Communication inc., National Campus and Community Radio Association, National Coalition of Canadian Ethnic Broadcasters, Ontario Association of Broadcasters, Pattison Media, Prince Edward County Radio Corporation, RNC MEDIA INC., Rogers Media Inc., Sirius XM Canada Inc., Stingray Group Inc., The Davies Company – Broadcast Solutions, The University of Calgary Student Radio Society, Torres Media, Trent Radio, Vista Radio Ltd.

  1. The Commission has heard that AI tools are used for radio programming, such as AI-generated scriptwriting and music scheduling.

    1. Is the industry working on any standard or code for AI use and disclosure, similar to a Code of Ethics?
    2. What is your organization's current policy or plan regarding the use of generative AI in your live broadcasts, specifically the roles that are traditionally performed by live talent, journalists, or programmers?

Section 6. Confidentiality, safeguards and data collection

ACCORD, ADISQ, Alliance nationale de l’industrie musicale, Amazon, Apple Canada Inc., Artisti, GMMQ et UDA, Association des professionnels de l’édition musicale, Canadian Independent Music Association, Canadian Starmaker Fund, DIMA, FACTOR, Fondation Musicaction, Fonds Radiostar, Forum for Research and Policy in Communications, Friends of Canadian Media, Indigenous Music Office, LATTICE-UQAM, Ontario Library Association, Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs, Songwriters Association of Canada, Spotify

  1. The Association des professionnels de l’édition musicale suggested in their written submission that the Commission collect a ranked list of the top 10,000-most streamed tracks in Canada from each registered audio streaming service.

    1. What specific insights could be derived from a ranked list of the top 10,000-most streamed tracks in Canada such as market share by origin, language or genre, and how could this data inform regulatory measures to enhance the discoverability and promotion of Canadian and Indigenous music?
    2. Is this sample size reflective of the music that is listened to on online audio services in Canada? After how many of the most streamed tracks would there be diminishing returns to understanding the audio content that is listened to in Canada?
    3. How often, and for what time interval should this data be reported?
Amazon, Apple Canada Inc., Canadian Association of Broadcasters, Canadian Starmaker Fund, Community Radio Fund of Canada, DIMA, FACTOR, Fondation Musicaction, Fonds Radiostar, Forum for Research and Policy in Communications, Friends of Canadian Media, Le Regroupement, Motion Picture Association-Canada, Ontario Association of Broadcasters, Spotify
  1. The Commission currently publishes revenue, expenditures, contributions to Canadian content and profitability data in the form of National and Regional level financial summaries, in addition to publishing this data at the entity level for large radio operators. These publications allow for accountability and transparency throughout the broadcasting system as well as ensure stakeholder access to relevant data for their participation and monitoring of the Canadian broadcasting system. Please comment on the possibility of the CRTC publicly releasing aggregated audio revenues and contribution expenditures at the entity level for all entities with ACGBR greater than $25 million.

Attachment 2: Distribution List

ACCORD
ADISQ
Alliance des radios communautaires du Canada
Alliance nationale de l’industrie musicale
Amazon
Apple Canada Inc.
Arsenal Media inc
Artisti, GMMQ et UDA
Association des professionnels de l'édition musicale
Awesome Productions and Management
Bayshore Broadcasting
Bell Media Inc.
Byrnes Communications Inc.
C.J.S.D. incorporated / Northwest Broadcasting / North Superior Broadcasting
Canadian Association of Aboriginal Broadcasters
Canadian Association of Broadcasters
Canadian Independent Music Association
Canadian League of Composers
Canadian Starmaker Fund
CBC/Radio-Canada
Chaires IANF - CREAT
CJ Radio
Cogeco inc., pour et au nom de sa filiale Cogeco Média inc.
Community Radio Fund of Canada
Corus Entertainment Inc.
DIMA
Durham Radio Inc.
FACTOR
Fondation Musicaction
Fonds Radiostar
Forum for Research and Policy in Communications
Friends of Canadian Media
Gary Mandin
Golden West Broadcasting Ltd.
Helix Records
Indigenous Music Office
LATTICE-UQAM
Le Regroupement
Leclerc Communication inc.
Makusham Musique
Motion Picture Association-Canada
Music Canada
National Campus and Community Radio Association
National Coalition of Canadian Ethnic Broadcasters
Nettwerk Music Group Inc.
Ontario Association of Broadcasters
Ontario Library Association
Panorama (formerly known as SOPROQ)
Pattison Media
Prince Edward County Radio Corporation
RAS Creative
*Re:Sound
RNC MEDIA INC.
Rogers Media Inc.
Screen Composers Guild of Canada
Sirius XM Canada Inc.
SOCAN
Société professionnelle des auteurs, compositeurs du Québec et des artistes entrepreneurs
Songwriters Association of Canada
Spotify
Stingray Group Inc.
Studio HAUSOFHAM
The Davies Company – Broadcast Solutions
The University of Calgary Student Radio Society
Torres Media
Trent Radio
Vista Radio Ltd.

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