We, the collective management organizations of the music industry—Music Authors’ Copyright Protection (MACP), Public Performance Malaysia (PPM) and Recording Performers Malaysia (RPM) have expressed concerns regarding the Guidelines of Copyright (Collective Management Organizations 2025) that was published on the official website of the Intellectual Property Corporation of Malaysia (MyIPO) on 17 January 2025 and referred to the media statement by the Minister of Domestic Trade and Cost of Living (KPDN), YB Datuk Armizan Bin Mohd Ali, from the Ministry of Domestic Trade and Cost of Living (KPDN) on 17 March, 2025.

During an engagement session held on 12 March 2025, organized by the Copyright Division of MyIPO with the management of collective management organizations (“CMO”), MACP, PPM, and RPM expressed our stance that the Guidelines had been published unilaterally without consultation with us and many provisions are ‘ultra vires’ meaning it exceeds the jurisdiction granted under the Copyright Act 1987 and conflict with other existing laws. As a result, we believe that the Guidelines should not be adopted by us.

While these CMO guidelines are said to be aimed at improving governance and operations of Collective Management Organizations (“CMO”) in Malaysia, the approach taken in their formulation raises serious concerns with the CMO and rights holders. We are of the view that certain provisions in the CMO Guidelines could excessively undermine the autonomy and independence of CMOs in carrying out our primary operational role—protecting the rights and interests of creators and copyright holders.

“All this while, MACP has operated with governance practices that adhere to international best practices. As a member of CISAC (International Confederation of Societies of Authors and Composers), we are subject to strict international regulations and guidelines established by CISAC. We respect the government’s efforts to improve the governance of the copyright industry; however, we have not been given sufficient opportunity to discuss and voice our perspectives. Without clear discussions with stakeholders, its implementation could negatively impact the copyright ecosystem and the livelihood of creators like myself, who rely on royalty income from collective management organizations.”

– Dato’ Mohd Nasir bin Mohamed, Chairman of MACP

“PPM is a Collective Management Organization (CMO) that represents the interests of copyright owners of music and video recordings, who are the primary investors in the local music industry. PPM is also a member of IFPI (International Federation of the Phonographic Industry), the global organization representing the recording industry. As an IFPI member, PPM continuously enhances its operations to align with global best practices. We welcome MyIPO’s initiative to publish the CMO Guidelines aimed at improving the governance of CMOs in Malaysia. However, this objective cannot be achieved without first conducting detailed consultations with us to ensure that the published CMO Guidelines genuinely protect the interests of the investors who are our members. On the contrary, flawed CMO Guidelines would negatively impact our company’s management, ultimately affecting investors’ revenue and the national economy. Therefore, we are prepared to collaborate with MyIPO to make the necessary amendments to the published CMO Guidelines to ensure they achieve their intended objectives.

– Rosmin bin Hashim, Chairman of PPM

“We appreciate the government’s efforts to enhance the governance of the copyright industry. However, as Collective Management Organizations in Malaysia, we are not only representing local artists but also international artists. Therefore, we have long been committed to governance practices that align with international standards. We remain steadfast in our responsibility to represent and protect copyright holders. Nevertheless, the implementation of these new guidelines presents many inconsistencies. We believe that we should be involved in discussions before any decisions or official guidelines are issued. These guidelines, which have the potential to disrupt our operations, inevitably risk affecting royalty payments to many artists. Without fair and transparent discussions, this could negatively impact the future of the music industry and the well-being of copyright holders.”

– Dato’ Hajah Sheila Majid, Chairman of RPM

As entities entrusted with safeguarding the rights of copyright owners, we firmly believe that any regulatory changes affecting the copyright industry must be implemented transparently, fairly, and through thorough consultations with all relevant stakeholders. Introducing these guidelines without adequate consultation could have negative repercussions on CMO operations, as well as the rights of creators, copyright holders, and other key players in Malaysia’s music industry.

We appreciate the authority’s assurance that the Guidelines will only be finalised after comprehensive stakeholder engagement. Therefore, we strongly urge the authorities to engage in open discussions with all stakeholders, especially those where the CMO Guidelines applies, to ensure that any regulatory changes do not compromise the interests of the music industry and copyright holders.

Additionally, we emphasize that any changes impacting the copyright industry must consider the needs and challenges faced by creators, copyright holders, and those who rely on an effective rights management system. CMOs have played a crucial role in ensuring that copyright holders receive fair compensation for their creative work. Any amendments to this system must safeguard their rights without unnecessary interference.

We urge KPDN and MyIPO to actively involve all stakeholders in open discussions and consultations. Such an approach will not only contribute to the development of more comprehensive guidelines but also ensure that Malaysia’s music and copyright industry continues to grow in a sustainable and equitable manner.

MACP, PPM and RPM remain committed to ensuring that Malaysia’s copyright management system remains fair, transparent, and aligned with existing laws in the best interests of creators and copyright holders

-Recording Performers Malaysia Berhad (RPM)