EIFL’s comments to the European Commission’s Call for Evidence supporting a review of the 2019 Copyright in the Digital Single Market (DSM) Directive focussed on two specific areas: facilitating research and sharing the results of publicly funded research.

First, EIFL called for the introduction of a robust, harmonized, mandatory research exception to address challenges for cross-border research collaborations, due to inconsistent implementations of Article 5(3)(a) under Directive 2001/29/EC (“Infosoc Directive”).

Second, EIFL called for an EU-level Secondary Publication Right (SPR) to address problems faced by academics in sharing, accessing and reusing the results of publicly funded research, as they often need to transfer their copyright to publishers when publishing in subscription-based scholarly journals. EIFL's submission included a model provision on SPR in copyright law, developed by EIFL in 2025, along with case studies from Repository Managers in Latvia, Armenia, Serbia and Moldova sharing their practical experiences obtaining and depositing published research and how a Secondary Publication Right would be of benefit.