Over 200 Sign Letter Opposing UMG’s Proposed Acquisition of Downtown

The campaign to prevent Universal Music Group from acquiring Downtown Music Holdings has intensified, with more than 200 representatives from independent music companies signing an open letter to Teresa Ribera, Executive Vice President of the European Commission, the watchdog that is currently assessing whether the UMG/Downtown deal requires in-depth investigation. The letter has been distributed by the Independent Music Companies Association (IMPALA).

Background:

• You can read a summary of the events leading up to this moment here.

• But in short, in December UMG’s Virgin Music Group announced it had agreed to buy Downtown Music Holdings LLC in a $775 million deal.

• The European Commission is currently carrying out Phase I of an investigation into the deal, which would determine whether a more in-depth investigation (Phase II) is necessary.

• The deadline for that decision is July 22.

• Last week Virgin co-CEOs Nat Pastor and JT Myers wrote to staff, correcting some of the perceived “fictions and falsehoods” around the deal.

The letter:

Signed by more than 200 CEOs, founders and business leaders across the independent music industry, the letter points to the fact that “UMG already controls over 40% of the recorded music market” across Europe.

It also raises significant concerns that the acquisition would threaten the effective competition, innovation, and growth of the EU’s music industry.

It states: “By absorbing Downtown's distribution, royalty accounting, and rights management capabilities – services used by thousands of companies and artists across the independent sector – UMG would further entrench its already significant market power.”

It adds: “This consolidation would further enable UMG to act as a gatekeeper to some of the sector's best services, shaping which music is heard, promoted, and monetised. Such power carries risks not only to the commercial fortunes of independent businesses, but to the creative breadth and diversity of music itself.”

Also: “[The deal] would reduce choice for consumers, stifle experimentation, and undermine Europe’s role as a vibrant incubator of musical and artistic expression.”

Signatories include representatives from Beggars Group, Secretly Group, Cargo Independent Distribution, Cooking Vinyl, Domino, Epitaph, Sub Pop, Playground and more.

The full letter is below.

4 July 2025

Dear Ms. Ribera,

We are the founders and CEOs of leading European and international music companies as well as trade associations. We normally write about music and culture and today we are also reaching out about competition.

On behalf of the independent music community, we are writing to express our serious concerns regarding the proposed acquisition of Downtown Music Holdings LLC (“Downtown”) by Universal Music Group N.V. (“UMG”), currently under investigation by the European Commission – Case M.11956.

The music industry in the EU is a cultural and economic success story, with recorded music revenue growing at 8.7% in 2023 and valued at €5.2 billion2. It is home to some of the most recognisable names in music, alongside thriving independent businesses.

But we can’t take this for granted. While the EU’s music industry is indeed growing, this growth is uneven and lags behind other global markets. At the same time, changes are being made to how streaming revenues are shared, over which the independent sector has no say. A level playing field is essential to support a thriving music ecosystem that delivers benefits for the economy, culture and innovation.

Everyone has a role to play – from the biggest music company in the world to the independent disruptive start-up uncovering new genres and sounds. But when acquisitions like this one occur and start to tip the scales too far, we must act.

The proposed acquisition by UMG represents a serious risk to that balance. Across Europe, UMG already controls over 40% of the recorded music market – near double the second biggest player3. By absorbing Downtown’s distribution, royalty accounting, and rights management capabilities – services used by thousands of companies and artists across the independent sector – UMG would further entrench its already significant market power.

The deal would place a significant chunk of essential infrastructure under the control of the market leader. Many independent music businesses are already tied to Downtown’s services, meaning that we would have to rely on our biggest competitor to connect our artists and their music to their fans.

That’s why it’s critical that the deal is reviewed through the lens of its “control share” over the digital markets economy, as well as the physical market, not just share by revenue.

This isn’t just a simple “investment” in one of the world’s most prominent independent companies; it is about control.

The implications are profound. This consolidation would further enable UMG to act as a gatekeeper to some of the sector’s best services, shaping which music is heard, promoted, and monetised. Such power carries risks not only to the commercial fortunes of independent businesses, but to the creative breadth and diversity of music itself.

A concentration of this magnitude would narrow the range of voices, styles, and cultures that reach the public. It would give UMG further power to shape digital services, influence monetisation thresholds and extract more, at the expense of the independent sector. That would reduce choice for consumers, stifle experimentation, and undermine Europe’s role as a vibrant incubator of musical and artistic expression. Fans will hear less of the new and more of the same. Artists working outside the commercial mainstream will struggle to find traction. And a once-thriving creative economy will begin to stagnate.

This acquisition also provides a key competitive advantage by allowing UMG to collect data from rivals using its services. This data is far reaching, from distribution information – including artists and song trends, and performance on digital platforms – all the way through to critical business information such as pricing, contractual terms and strategic relationships. Being able to access all of this data would give UMG backdoor access to other competing businesses in the market and strengthen its already advantageous position even further.

Independent music companies play a vital role in promoting music innovation, fostering diversity and protecting culture. To fulfil that role, we must have fair and non-discriminatory access to the best infrastructure in the music economy. And not be forced into structural dependence on our biggest competitor who is also shifting payment models on digital services.

We therefore urge the European Commission to open a detailed phase two investigation to examine the deeper structural consequences of this transaction. The proposed acquisition poses a clear threat to effective competition, innovation, and the growth of the music industry across the EU and globally.

We must keep music open.