Subject: FW: [Päring#1000478389] [dh.jum] FW: Urgent request for a meeting ahead of Digital Omnibus discussions in the Council - inde [...]
From: "Stina Avvo - JUSTDIGI" <[email-masked]>
To: "Justiits- ja Digiministeerium" <[email-masked]>
Date: Mon, 18 May 2026 18:45:27 +0300

Stina Avvo
juhataja
Justiits- ja Digiministeerium
58851218

From: Stuart Wilkinson <[email-masked]>
Sent: Monday, May 18, 2026 3:51 PM
To: Stina Avvo - JUSTDIGI <[email-masked]>
Cc: Lauri Luht - JUSTDIGI <[email-masked]>; Margo Veskimägi
<[email-masked]>; Marie De Cordier
<[email-masked]>
Subject: RE: [Päring#1000478389] [dh.jum] FW: Urgent request for a meeting
ahead of Digital Omnibus discussions in the Council - inde [...]

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Dear Ms Avvo

Thank you for sending the email below.

There may be a little confusion as I wrote to you about audience
measurement and the Omnibus drafting around clauses 88a and 88b and now
the subsequent Cyprus Presidency drafting that puts 88a into amendments on
ePrivacy Directive.

Your response is focused on AI which is another area of the law.

We have met with several industry stakeholders in recent weeks, including
Capitals and their Representatives in Brussels, and are grateful to see
that the terrible impact the current drafting will have on the
sustainability of independent measurement of the media ecosystem is being
taken onboard now. By them.

Namely we note that France, Italy, Germany, Denmark, Sweden, Finland, and
Poland recognise that the current drafts endanger independent measurement.
If passed the new law will lead to the inability to confidently trust and
interpret data on audience consumption of media in Europe.

Some of this becomes technical, particularly around the concept of
immediate aggregation. The impact of such would essentially mean there is
no path for independent verification of media data. There will be no means
of checking the reliability of claimed data, nor will it be comparable -
key tenets of the recently passed European Media Freedom Act (Art 24).

If you have any time, it would be great to speak with you to discuss the
issues at hand so this can inform the forthcoming continued drafting
process.

I have attached our position paper for your consideration.

Thanks and best regards

On behalf of Audience Measurement Coalition (AMC)

www.audiencemeasurementcoalition.eu
<http://www.audiencemeasurementcoalition.eu/>

Stuart Wilkinson

Fifty5Blue

Board Member of AMC

Confidential

From: Stina Avvo - JUSTDIGI <[email-masked]
<mailto:[email-masked]> >
Sent: 05 May 2026 21:53
To: Stuart Wilkinson <[email-masked]
<mailto:[email-masked]> >
Cc: Lauri Luht - JUSTDIGI <[email-masked]
<mailto:[email-masked]> >; Margo Veskimägi
<[email-masked] <mailto:[email-masked]> >;
Marie De Cordier <[email-masked]
<mailto:[email-masked]> >
Subject: RE: [Päring#1000478389] [dh.jum] FW: Urgent request for a meeting
ahead of Digital Omnibus discussions in the Council - inde [...]

Dear Mr Wilkinson

Thank you for sharing your views and AMC’s position papers on the Digital
Omnibus with us. We have carefully reviewed your positions.

Estonia does not support the proposal to regulate artificial intelligence
as a specific technological solution within the framework of the General
Data Protection Regulation (GDPR). Estonia maintains that the principle of
technological neutrality of the GDPR must be preserved. At the same time,
amendments introduced under the Digital Omnibus must not result in making
the deployment and training of artificial intelligence more complex than
they are at present. The processing of personal data for the purposes of
technological development must be possible on all legal bases for data
processing provided for in the GDPR.

As Article 5b of the ePrivacy Regulation is a new addition, it remains
under scrutiny.

Our national mandate for the Digital Omnibus can be found here:
https://www.riigikogu.ee/tegevus/dokumendiregister/dokument/672021a6-27aa-
42f2-a508-cb7b39310189/ (available in Estonian only).

Kind regard

Stina Avvo
Chief Legal Officer (IT law)
Ministry of Justice and Digital Affairs
+372 58851218

From: Justiits- ja Digiministeerium <[email-masked]
<mailto:[email-masked]> >
Sent: Friday, April 24, 2026 1:51 PM
To: Justiits- ja Digiministeerium <[email-masked]
<mailto:[email-masked]> >
Subject: FW: [Päring#1000478389] [dh.jum] FW: Urgent request for a meeting
ahead of Digital Omnibus discussions in the Council - inde [...]

From: Stuart Wilkinson <[email-masked]
<mailto:[email-masked]> >
Sent: reede, aprill 17, 2026 4:56 PM
To: Lauri Luht - JUSTDIGI <[email-masked]
<mailto:[email-masked]> >
Cc: Margo Veskimägi <[email-masked]
<mailto:[email-masked]> >; Marie De Cordier
<[email-masked] <mailto:[email-masked]> >
Subject: Urgent request for a meeting ahead of Digital Omnibus discussions
in the Council - independent audience measurement at stake

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Dear Mr. Luht,

I am writing to you as the Managing Director of International Digital
Business Development of Fifty5Blue, formerly called Kantar Media, and as a
Board Member of the Audience Measurement Coalition (AMC), a trade
association representing 25 Joint Industry Committees and market research
suppliers across Europe.

The Members of the AMC provide the trusted, official audience measurement
essential for a healthy, fair media market and public oversight—a function
that my company fulfils for the media industry in Estonia under the EMOR
organisation  https://www.emor.ee/who-we-are/ managed by Margo Veskimägi,
head of our Baltics division.

To be quite concise the European media industry’s institutions that
provide independent measurement of media audiences in the digital age
faces what must be seen as a potentially catastrophic situation regarding
the Proposal for a Digital Omnibus Regulation, specifically Article
88a(3)(c).

The Commission's wording jeopardizes the critical general and
public-interest function of independent measurement, but our concerns have
been amplified into potential crisis by the latest leaked draft Council
compromise text (the now article 5 and recital 44)

The Proposal for a Digital Omnibus Regulation and the proposed compromise
text create an immediate legislative conflict with the 2024 European Media
Freedom Act (EMFA).

By introducing a direct, competing definition in recital 44, the Proposal
doesn't merely contradict the EMFA, it actively nullifies its authority,
reducing the established EU instrument to a symbolic gesture.

It also establishes a legal basis that actively favours dominant
platforms, mostly non-EU in origin and predominantly US-based,  for
internal measurement, while the new technical specifications (in recital
44) and the forced 'processor' role for third parties immediately outlaw
independent, verifiable market-agreed audience measurement.

This legislative paradox will strip the media market of its essential
mechanism for transparency and competition, preventing the entire sector
from functioning properly.

Moreover, fundamental public interests are now critically at stake.

Independent, impartial measurement is provided to Ministries and public
administrations across Europe for essential public oversight functions,
such as media concentration assessments, election monitoring, distribution
of public funds, and AVMSD Compliance (protection of minors), among
others.

The proposed text nullifies our ability to provide that measurement
independently and without risk of interference of the very media we are
institutionally mandated to independently measure.

Given the extreme urgency we would be grateful for an exchange before the
Council meeting dedicated to the Digital Omnibus on 24 April. This text's
consequences could cause irreparable harm to independent audience
measurement and European digital transparency.

Please find attached the AMC's position paper, detailing the precise and
essential amendments required to safeguard the future existence of
independent audience measurement.
I am also copying the recently published Latvian position that clearly
recognises the threat that the current Council draft to an independent and
independently measured European media industry and society.

Thank you for your immediate attention to this critical matter.

Yours sincerely,
On behalf of the AMC
Stuart

Stuart Wilkinson
Managing Director International Business Development, Fifty5Blue (formerly
Kantar Media)

https://audiencemeasurementcoalition.eu/

Cc:       Marie de Cordier, Nielsen. General Secretary of AMC
              Margo Veskimägi, Head of Baltics EMOR, Fifty5Blue

Confidential

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