Photo Credit: JP Valery
A2IM led a coalition of indie orgs in filing a formal complaint with the U.S. Copyright Office, opposing the proposed 43% registration fee increase.
On Monday, the American Association of Independent Music (A2IM) filed formal comments with the U.S. Copyright Office, leading a coalition of independent music organizations in opposing the Office’s proposed 43% average increase to copyright registration fees. Together, the coalition represents the working core of America’s independent music community and the tens of thousands of recording and performing musicians, songwriters, and managers whose livelihoods depend on accessible and fair copyright registration.
Joining A2IM in the filing are the Artist Rights Alliance, Music Managers Forum-US, The Recording Academy, Society of Composers & Lyricists (SCL), Songwriters of North America (SONA), Songwriters Guild of America (SGA), Music Artists Coalition (MAC), American Federation of Musicians (AFM), and the Future of Music Coalition.
The filing argues that the Copyright Office’s proposed fee schedule, published in March, fails to give “due consideration” to the statutory objectives of the copyright system and would impose a disproportionate burden on independent creators who are “structural price-takers” in the music economy.
Unlike major labels, independent labels and individual creators cannot simply shrug their shoulders when it comes to cost increases. Others set the price of their primary income streams, from streaming royalties determined by the major DSPs to mechanical royalties calculated by the Copyright Royalty Board.
“The Copyright Office’s mission is to serve every American creator, not just those with the most resources,” said A2IM CEO Ian Harrison. “A 43% fee hike, imposed on independent artists and labels who are already navigating compressed streaming royalties, stagnant per-stream rates, and no ability to pass through costs, is not cost recovery: it is a barrier to justice.”
“Registration is the gateway to enforcement, and if we price independent creators out of that gateway, we are dismantling the very infrastructure that makes copyright meaningful for the people who need it most. A2IM urges the Copyright Office to reconsider this proposal and to stand with the full, diverse community of American rightsholders it was created to serve,” Harrison concluded.
The coalition’s comments highlight several key concerns. The fee increases would accelerate an already low registration rate among independent creators, undermining copyright’s core incentive function. Independent music accounts for over 35% of the U.S. market share, reflecting the democratization of creative production that the copyright system is designed to encourage. But without accessible registration, that market participation does not translate into enforceable rights.
The filing also highlights the legal distinction between copyright registration and other government user fees, such as patent prosecution or FDA drug approval fees. Unlike those fees, which grant a new right, copyright registration is a prerequisite for enforcing an existing right. Statutory damages, attorney’s fees, and access to the Copyright Claims Board all require prior registration. A fee increase that deters registration, thereby raising the price of access to a system designed to be affordable.
“Independent artists and the labels and managers who support them have always ha to do more with less,” said A2IM COO Lisa Hresko. “What they cannot do is absorb a 43% fee increase on top of shrinking royalty rates and no leverage to demand more. The Copyright Office should be expanding access to the registration system, not making it more expensive.”
