Transparency reports — Article 19 / S.I. 567/2021
Transparency reports are the producer's statutory obligation to report regularly to talent with profit-participation deals — writers, directors, composers, lead performers, etc. — on the exploitation of the work they contributed to. Established at EU level by Article 19 of Directive 2019/790 and transposed into Irish law as S.I. 567/2021.
The obligation
A producer who has acquired rights from a writer / director / composer / performer who has a residual / profit-participation interest must, at least annually, provide that party with:
- Mode of exploitation per territory
- Revenue generated
- Producer's costs deducted
- Net profits or producer's share
- The recipient's share calculated against their participation rate
- Information that allows the participant to assess fairness
The strict reading of the SI: a producer who hasn't issued a full set of reports for any reporting period more than 12 months old is non-compliant.
Jurisdiction matters
The legal basis cited on the transparency report is driven by the recipient's country of residence, not the producer's:
| Recipient residency | Legal basis cited |
|---|---|
| Ireland | S.I. 567/2021, Reg. 19 |
| United Kingdom | Contract terms (UK didn't transpose post-Brexit; reporting on EU exploitation falls back to the local state's law) |
| Germany | UrhG §32d |
| France | CPI L131-5-1 |
| Netherlands | Auteurswet 25ca |
| Spain | Spanish IP Law transposition |
| Italy | Italian Copyright Law transposition |
In Togra
Producer-side: /transparency.php (slate-wide) and /transparency-project.php (per-project periods + recipients); publish via /transparency-publish.php; the slate-wide compliance dashboard (6 KPIs) is /transparency-compliance.php.
Recipient-side: tokenised view at /r.php?t=<token> with inline glossary + ability to file queries or objections.
Talent-side: cross-producer aggregator at /worker-transparency.php — a writer with deals at three different producers signs into one Togra account and sees every report addressed to their email across all those producers.
Related
- CAMA — Contract Adjustment Mechanism — Composers' Annual Music Audit, where Irish-law CAMA applies on top of the transparency obligation
- Residual obligations — the underlying contractual structures that drive what gets reported
- Net profits — the calculation basis — the calculation basis
Related
Sources
- · EU Directive 2019/790, Article 19
- · S.I. 567/2021 — Ireland transposition
- · UrhG §32d (Germany) · CPI L131-5-1 (France) · Auteurswet 25ca (Netherlands)