The Adequacy of Music Streaming Royalties for Australian Artists

The last decade has seen the rapid digitalisation of most media and
entertainment industries.1 The introduction of streaming services in the music sphere
has sparked an ongoing discussion about the future of music and technology, and how
artists have been impacted financially. 2 Spotify, Apple Music and other major platforms
are replacing older forms of access to music, such as downloading, and are becoming
the dominant providers of music consumption. 3 The primary research question is: how
has the rise in popularity of online music streaming services financially impacted
Australian artists and is policy change necessary? Following an overview of the way in
which streaming services obtain the rights to music so as to avoid copyright and how
they pay their artists, the adequacy of the royalties that Australian artists receive is
discussed. The suggested changes made by music unions and advocacy groups are
considered along with the arguments made regarding piracy and artist promotion which
defend the streaming service payment models.

Overview of Streaming
Like many industries, the music industry is constantly developing new
technologies and updating online platforms in order to keep up with the rapid
digitalisation of the world.4 Accompanying these developments are alterations to
business models and the system of providing income for artists. 5 Digital technology was
originally very beneficial for all parties with the introduction of the CD resulting in a
boom in music sales and providing consumers with a portable music player. 6 The next
significant development was the creation of the MP3 audio format in 1993. 7 ‘Peer to

1
Luis Aguiar and Bertin Martens, “Digital Music Consumption on the Internet: Evidence from Clickstream
Data” (2016) 34 Information Economics and Policy, 27.
2
Peter Godfrey-Smith, ‘Does the Rise of Streaming and Downloading Mean the Loss of Music?’ ABC
News (2016) <https://www.abc.net.au/news/2016-11-27/the-loss-of-music/8054902>
3
Ibid.
4
Peter Verhoef Thijs Broekhuizena, Yakov Bartb, Abhi Bhattacharya, John Qi Dong Nicolai Fabian and
Michael Haenlein, “Digital Transformation: A Multidisciplinary Reflection and Research Agenda” (2021)
122 Journal of Business Research 889 - 901.
5
Ibid.
6
Theodore Giletti, ‘Streaming, Downloading, and Digital Music Consumption in the “ITunes Era”’ (MMC
Dissertation, London School of Economics and Political Science, 2011).
7
Ibid.
peer’ networks such as Napster allowed MP3 files to be downloaded and transferred to
any device, thus making the “core scarce good of recorded music infinitely replicable” 8
The latest music distribution technology is streaming which allows a listener to play any
song on demand without having to retain possession of it after downloading its
contents.9 This new technology has meant that anyone with any piece of smart
technology can access a seemingly endless library of music. 10 Streaming is therefore
often seen as a luxury for consumers. 11 However, for artists and producers it is often
described as a detriment due to the adverse financial consequences of such easy
access to their music.12
Spotify, Apple Music and Pandora Radio are just a few of the popular music
streaming services that are rapidly replacing downloading services such as the iTunes
Store.13 Spotify in particular, which launched in Australia in 2012, was the first service to
offer a free membership that is based on an advertising model which includes per song
pop-up adverts that can not be skipped. 14 Removing these advertisements is available
for a monthly subscription fee.15 Apple Music, which launched in 2015, offers customers
a three month free trial before requiring a monthly subscription fee. 16

Overview of Copyright
Copyright is a statutory right which subsists in original literary, dramatic, musical
and artistic works, and in subject matter in material form. A song recording usually
consists of three separate forms of copyright. The first is the copyright in the recorded

8
Nancy K. Baym, “The Swedish Model: Balancing Markets and Gifts in the Music Industry” (2011) 9(1)
The International Journal of Media and Culture, 177.
9
n 6.
10
Aoife Coffey, ‘The impact that music streaming services such as Spotify, Tidal and Apple
Music have had on consumers, artists and the music industry itself.’ (Dissertation, University of Dublin,
2016).
11
Ibid.
12
n 10.
13
Adam Arnaout, The Future Runs Downstream: The Evolution of Digital Music Services and Music
Streaming (Report, 2016), 2.
14
Matt Hopkins, ‘Popular Australian Musicians Make Less on Streaming Services like Spotify than You
Might Think’ Business Insider Australia (2020). <https://www.businessinsider.com.au/australia-streaming-
music-2020-4>
15
Ibid.
16
Ibid.
musical works which is the ‘combination of sounds for listening to’. 17 The second is the
copyright in the song lyrics known as the literary work. Section 35 of the Copyright Act
1968 (the Act) states that the owner of any copyright subsisting in original musical and
literary works is the author of the works. 18 However, this can vary by contract via
assignment or ‘prospective ownership of copyright’ 19. There can also be works of joint
ownership which is defined in section 10 of the Act as ‘a work that has been produced
by the collaboration of two or more authors and in which the contribution of each author
is not separate from the contribution of the other author or the contributions of the other
authors’.20 In order for a music streaming platform to be able to legally make songs
available for streaming, a license from these copyright owners is required. 21 In Australia,
these licenses can be obtained through collecting society the Australasian Performing
Right Association Limited and the Australasian Mechanical Copyright Owners Society
Limited (APRA- AMCOS).22 The streaming service pays a royalty fee based on their
revenue which the collecting societies distribute to the copyright owners in proportions
corresponding to the number of streams or downloads. 23
The third form of copyright is in the sound recording itself. The copyright that
subsists in the sound recording is in addition to, but independent of, the copyright in
musical and literary works.24 In the case of a sound recording, the owner is not the
author, but rather, the maker. A maker, according to section 22(3)(b) of the Act, is the
owner of the master record.25 The maker can be the independent performer or
performers on the recording, however, it is more common for a record company to be
the owners of this copyright.26 Contracts will often stipulate that the record company will
be the sole owner of the master and therefore have the power to license the music out

17
Hyperion Records Ltd v Sawkins [2005] EWCA Civ 565.
18
Copyright Act 1968 (Cth) s 35.
19
Copyright Act 1968 (Cth) s 197.
20
Copyright Act 1968 (Cth) s 10.
21
Arts Law Centre of Australia, ‘Music Streaming Services and Licensing Fees – How Do Artists Fare?’
Arts Law Centre of Australia: The national community legal centre for the arts (2012)
<https://www.artslaw.com.au/article/music-streaming-services-and-licensing-fees-how-do-artists-fare/>
22
APRA AMCOS, ‘What We Do’ Apraamcos.com.au (2020) <https://apraamcos.com.au/about-us/what-
we-do/>
23
Ibid.
24
Copyright Act 1968 (Cth) s 113.
25
Copyright Act 1968 (Cth) s 22(3)(b).
26
n 13.
to other parties.27 Copyright owners have exclusive rights attached to their sound
recordings such as the right to copy it, to cause it to be publicly performed, the right to
enter into commercial rental agreements in relation to the recording, and the right to
communicate it to the public.28 By making music available for streaming, music
streaming services are communicating the sound recording to the public. To obtain this
right, they therefore require a license from the owner of the sound recording. 29
Music streaming services negotiate with owners, commonly the record company,
and enter into deals for access (i.e. gain a license) to their catalogue of music. These
deals include an upfront payment to the record label and payment for every time a song
has been streamed.30 Spotify, for example, has reportedly paid millions of dollars in
upfront licensing fees and has deals with the three major record labels, Universal Music
Group, Sony Music Entertainment Group and Warner Music Group. 31 In 2006 when
Spotify was first launched, it paid record labels over $180 million upfront on royalty
payments.32 The record labels then pay the artists a proportion of the money earned
which is determined by the recording contracts signed. Artists who are not signed with a
major record label can make their music available on music streaming services via artist
aggregators and independent record labels. 33 However, smaller artists are often offered
lower licensing rates as they do not have as much bargaining power as the major record
labels, which raises the issue of whether music streaming services are adequately
paying artists.34

Adequacy of Royalties
27
n 21.
28
Copyright Act 1968 (Cth) s 85.
29
n 22.
30
Ibid.
31
Matt Binder, ‘Three Major Music Labels Make $19 Million a Day from Streaming While Artists Count
Their Pocket Change’ Mashable (2019). <https://mashable.com/article/major-music-labels-19-million-per-
day-streaming/>
32
Ibid.
33
APRA AMCOS, ‘How to: Get Music on Spotify, ITunes, Pandora and Beyond’ Apraamcos.com.au
(2016) <https://apraamcos.com.au/news/2016/april/how-to-get-music-on-spotify-itunes-pandora-and-
beyond/>
34
n 2.
 Music Australia estimates that the music industry contributes somewhere
between $4 billion to $6 billion to the Australian economy each year. 35 The Australian
Recording Industry Association (ARIA) estimates that the recorded music industry alone
generated $555 million in revenues in 2019, which is a 5.5 percent increase from
2018.36 These figures may indicate that Australian artists are thriving. However, in many
cases, artists are not receiving very much payment at all. 37 This is a particularly relevant
issue within the music streaming context. There has been an ongoing discussion
regarding whether streaming services are paying artists, especially independent artists,
adequate royalties since the streaming services began. A large portion of Australian
musicians cannot rely solely on the income from their music, with 56 percent earning
less than $10,000 per year and only 16 percent earning over $50,000 per year. 38
Further, only a small portion of this amount comes from streaming services revenue and
royalties.39
Music streaming services generally pay music owners at a certain rate per
stream, however, on all major music platforms, this rate is objectively low. The average
pay rate for one stream of a song is $0.004 on Spotify and Amazon Music, $0.008 on
Apple Music, $0.007 on Google Play music and $0.001 on Pandora Radio. 40 The rate
can vary depending on which country the music is being streamed in, whether the
listener has a paid subscription or a free account and on whether the artist has a
specific royalty rate.41 For very popular artists who receive streams over the one million
mark, a substantial amount of money can be made. For example, two of Australia’s
35
Music Australia, ‘Australian Contemporary Music Industry: A multi-billion dollar contributor to Australia’s
economy & culture’ Music Australia (Report, 2017)
<https://musicaustralia.org.au/wp-content/uploads/2017/08/Australian-Contemporary-Music-a-billion-
dollar-industry_2017.pdf>
36
Australian Recording Industry Association, ‘Music Industry Figures Show 5.5% Growth’ ARIA (Blog
Post, 2019) <https://www.aria.com.au/charts/news/aria-2019-music-industry-figures-show-55-percent-
growth>
37
Matt Hopkins, ‘Popular Australian Musicians Make Less on Streaming Services like Spotify than You
Might Think’ Business Insider Australia (Blog Post, 2020). <https://www.businessinsider.com.au/australia-
streaming-music-2020-4>
38
David Throsby and Anita Zednik, ‘Do You Really Expect to Get Paid? An Economic Study of
Professional Artists in Australia’ Australia Council for the Arts, Australian Government (Report, 2015).
<https://www.australiacouncil.gov.au/workspace/uploads/files/research/do_you_really_expect_to_get_pa-
54325a3748d81.pdf>
39
Ibid.
40
Ditto Music, ‘How Much Do Music Streaming Services Pay Musicians in 2020’ Dittomusic.com (Blog
Post, 2020). <https://www.dittomusic.com/blog/how-much-do-music-streaming-services-pay-musicians>
41
Ibid.
biggest artists during 2019, Dean Lewis and Tones and I, made $4.7 million from 734.1
million streams and $3.1 million from 482.5 million streams, respectively. 42 However,
smaller artists who are not mainstream artists with a large following do not receive
millions of streams and the overall payment is usually very little. The Music Network
calculated that in order to make $500 per fortnight, a band with four members would
need to achieve 632,656 Spotify streams every month. 43
Each platform has fought controversy regarding how it pays their artists. For
example, American singer and songwriter Taylor Swift removed her music from Spotify
in 2014 due to her belief that their payment system was unfair to smaller songwriters all
over the world.44 Swift disliked the fact that members with the free subscription plan
have access to music and that this offer devalues the hard work of musicians. 45 Swift
also campaigned for Apple Music to pay artists even during a consumer’s three month
free trial and wrote in a Tumblr post that: ‘three months is a long time to go unpaid, and
it is unfair to ask anyone to work for nothing’ and wishes for them to change their
policy.46

Policy Change
The Australian music community have been advocating for various kinds of
policy changes with the overall aim of achieving adequate payment for musician's work.
In 2018, Mitch Fifield, Minister for Communications and the Arts, requested an inquiry
into the “factors contributing to the growth and sustainability of the Australian music
industry.”47 A number of participants in this inquiry revealed that they believe streaming
services are unintentionally devaluing recorded music. 48 The Association of Australian
Musicians (AAM) stated that ‘Spotify’s micro royalty payments have put many musicians

42
n 14.
43
Staff Writer, ‘About 1% of artists generate 90% of all music streams’ The Music Network (Report, 2020)
<https://themusicnetwork.com/few-artists-generate-most-streams/>
44
n 10.
45
Ibid.
46
Taylor Swift, ‘To apple, Love Taylor’ Tumblr (Blog Post, 2015)
<http://taylorswift.tumblr.com/post/122071902085/to-apple-love-taylor>
47
Parliament of Australia, “Inquiry into the Australian Music Industry” Aph.gov.au (Report, 2018), 12.
<https://www.aph.gov.au/Parliamentary_Business/Committees/House/Communications/
Australianmusicindustry>
48
Ibid.
out of business’.49 Since this report, the 2020 global pandemic, Covid-19, has
exacerbated these financial inequalities that small Australian musicians have already
been battling for years. Artists are more reliant than ever on profits from streaming
services as live shows and events have been placed on hold. 50
These circumstances have caused musicians to join unions and other advocacy
organisations with the aim of fighting for fairer payment. The Director of the industry
union Musicians Australia Paul Davies has said that music streaming services are:
“purely exploitative. It's straight out exploitation that allows large corporations to
basically monopolise the industry and dictate terms." 51 Davis further explains that he is
cynical of the usefulness of the parliamentary inquiry because these issues have been
known about for decades and no action has been taken. Additionally, Musicians
Australia have stated that the payment issues are too complex to be solved with “one-
size-fits-all solutions” and multiple changes need to occur. 52
Demanding policies that require streaming services to make larger payouts per
stream seems to be the most desired change. However, increasing pay rates per
stream is not the only change to the system that could benefit Australian artists.
Similarly, advocates have suggested that collecting societies also increase their rates.
This follows the U.S. initiative by the American Copyright Royalty Board which ruled that
they will increase their rates by 43.8 percent by 2023, allowing artists to receive larger
payouts.53 Another change that has been proposed by the music community is for the
streaming services to increase their subscription fees. This would increase revenue and
allow the services to increase the payout to the rights holders. An issue with this
proposal however is that suddenly requesting consumers to pay more for each
49
Ibid.
50
Paul Crosby and Jordi McKenzie, ‘Survey Evidence on the Impact of COVID-19 on Australian
Musicians’ Macquarie University (Report, 2020) <https://researchers.mq.edu.au/en/publications/survey-
evidence-on-the-impact-of-covid-19-on-australian-musicians>
51
Ange McCormack,’ Should Spotify pay more per stream? How artists have to play the 'digital marketing
game' in 2020’ ABC’s Triple J Hack (Blog Post, 2020).
<https://www.abc.net.au/triplej/programs/hack/should-spotify-pay-more/12892046>
52
Musicians Australia “A Plan for Change” Musiciansaustralia.org.au (Report, 2019)
<https://musiciansaustralia.org.au/?
utm_source=google&gclid=CjwKCAiAtej9BRAvEiwA0UAWXvN2zUQBG152z_F2kKv9iH7_tV6NWWpyUA
Z_AcetA5JozdwIclcqRhoCqBoQAvD_BwE#block65>
53
Michelle Castillo, “Spotify IPO Filing Reveals How Insanely Complicated It Is to License Music Rights,”
CNBC (Blog Post, 2018) <https://www.cnbc.com/2018/02/28/how-spotify-licenses-and-pays-for-music-
rights.html>
subscription may not be the most effective change. A representative from the Keep
Music Alive Alliance made a statement saying: “ given where we are economically right
now, and pressure on peoples’ wallets, [increasing subscription fees] is probably not the
route to go down as a campaign.” 54
Musicians have also been advocating for increased payment through
government programs and grants. 55 However, the issue with the arts relying on the
government is that there is too much vulnerability, instability and uncertainty in politics. 56
There is an argument that changing the way in which the music streaming services are
dividing up the funds may make a significant difference to this issue. 57 For example,
Spotify and Apple Music currently operate under a ‘pro rata’ system which collects a
certain percentage of the total money generated from users and divides this amount
proportionally by the amount of streams artists receive. Professor of music business at
the College of Music in Berklee George Howard says that only the very popular artists
make money from this system and who each individual user supports is not
considered.58 The suggested alternative is a ‘user-centric’ system. This model allows
the specific artists that an individual streams to exclusively receive that user’s money,
increasing the amount of payment smaller artists receive. 59 While theoretically this
system makes sense, dealing with millions of users individually would itself cost
streaming services more money, reducing the amount they could pay rights holders. 60
Although these suggestions for change appear useful, they are not always viable and
straightforward.

Streaming Service’s Response

54
The Ivors Academy “The Ivors Academy and Musicians’ Union Launch Keep Music Alive Campaign to
‘Fix Streaming Now’” The Ivors Academy (Blog Post, 2020) <https://ivorsacademy.com/news/the-ivors-
academy-and-musicians-union-launch-keep-music-alive-campaign-to-fix-streaming-now/>
55
n 2.
56
Ibid.
57
Alyssa Meyers, ‘Popular Australian Musicians Make Less on Streaming Services like Spotify than You
Might Think’ Business Insider Australia (Blog Post, 2020). <https://www.businessinsider.com.au/how-
apple-music-and-spotify-pay-music-artist-streaming-royalties-2020-1?r=US&IR=T>
58
Ibid.
59
Ibid.
60
Ibid.
 Music streaming services have responded to criticism about the fairness of their
payment models with various arguments pertaining to how they compare with older
models of music consumption. As previously mentioned, the streaming model is a
departure from the downloading model that was popular through the early 2000s. 61
Downloading music began in 2003 when Apple launched their iTunes Store which was
designed to be used in conjunction with their MP3 music player, the iPod. 62 Customers
are required to pay $0.99 per song. Apple keeps a small portion of the payment, with
the remaining going straight back to the labels which pay the artists according to their
contract terms.63 Apple does not require licensing agreements and there is no cost for
artists to join the store, unlike the deals that have to be made when joining streaming
services such as Apple Music for example. With artists being paid more from
downloading a song or an album, the music industry is disgruntled by the fact that
streaming services are replacing this source of income and lessening the amount of
money they are receiving. Spotify responded to this by arguing that their service is
‘revenue neutral’.64 In the last decade, piracy has been a major threat to artist’s
revenues.65 While streaming services may replace revenue that consumers would have
normally spent on digital download purchases, this money is actually still being pooled
into the music industry as streaming services have caused a decline in piracy. 66 It is
argued that this reduction is balancing out revenue flow and streaming services are
identifying themselves as ‘piracy-fighters’ in an attempt to counteract the controversial
nature of their royalty payment systems.67
Since streaming services have increased in global popularity, copyright laws in
Australia have strengthened. In 2015, section 115A of the Copyright Act 1968 68 has
61
n 9.
62
Mixdown, “Musicology: The History of Music...,” mixdownmag (Blog Post, 2017)
<https://mixdownmag.com.au/features/columns/musicology-the-history-of-music-streaming/>
63
Kristin Thomson and Brian Zisk, ‘iTunes and Digital downloads: An Analysis” Future of Music Coalition
(Blog Post, 2003) <http://futureofmusic.org/article/article/itunes-and-digital-downloads-analysis>
64
Peter Kafka, ‘How Can Spotify Shrink and Grow the Music Business at the Same Time?’ Vox (Blog
Post, 2015) <https://www.vox.com/2015/10/28/11620140/how-can-spotify-shrink-and-grow-the-music-
business-at-the-same-time>
65
Jelle Janssens, Stijn Van Daele and Tom Vander Beken, “The Music Industry on (the) Line? Surviving
Music Piracy in a Digital Era,” (2009) 17(2) European Journal of Crime Criminal Law and Criminal Justice,
77-96.
66
Ibid.
67
Ibid, 1.
68
Copyright Act 1968 (Cth) s 115A.
allowed copyright holders to seek injunctive relief against an online location that has the
primary purpose of infringing, or facilitating the act of infringing, copyright. 69 This
provision was broadened by the implementation of Copyright Amendment (Online
Infringement) Act 201870 as the test was expanded to include the 'primary purpose or
the primary effect' of a site to be copyright infringement. 71 These changes have forced a
decline in illegal downloads and piracy which in turn has seen an increase in paid music
streaming subscriptions.72 The Australian Copyright Council (ACC) have said that they
are satisfied with the current protection provisions in the Copyright Act. In the 2018
parliamentary inquiry into the music industry, they provided a statement saying: “The
[current] rights are good, and we have fair exceptions to copyright, and rights can be
enforced. It's extremely expensive for individuals to exercise their rights through the
court system, but there are big collective organisations that do a lot of that work for
them.”73
An additional argument that streaming services are making is that their platforms
are an invaluable tool for exposure and career development. The CEO of Spotify, Daniel
Ek, estimated that over 40,000 songs are added to music services each year, making it
less likely for consumers to find and then immediately purchase smaller artist’s music. 74
Owner of MTS Records and Management Group Michael Stover compared the services
to the radio in the following statement:
Streaming sites like Spotify are there for music discovery, promotion, and a way
for artists to have their music heard by an audience that wouldn’t normally listen.
Is someone going to buy your music when they’ve never heard of you before?
Most likely, no. But with streaming, and especially getting on playlists, the
opportunity to get discovered by new listeners, and essentially, customers,
opens the doors to an audience you wouldn’t have otherwise had. 75

69
Fernanda Dahlstrom, ‘Digital Piracy and the Copyright Act’ Go To Court (Blog Post, 2017)
<https://www.gotocourt.com.au/civil-law/digital-piracy-copyright-act/>
70
Copyright Amendment (Online Infringement) Act 2018.
71
n 42.
72
n 43.
73
n 37, 8.
74
Tim Ingham, “Nearly 40,000 Tracks Are Now Being Added to Spotify Every Single Day,” Music
Business Worldwide (Blog Post, 2019) <https://www.musicbusinessworldwide.com/nearly-40000-tracks-
are-now-being-added-to-spotify-every-single-day/>
75
n 74.
Even if policies and regulations are put in place to increase the amount of payment
received from streaming services, it will likely not be enough to support most artists. In
an interview for The Economist, hip-hop and rap artist Jaleel Koth reinforced the idea
that streaming services are designed for promotion and growth. 76 He went on to further
state that the best way to support an artist is by attending their live shows, purchasing
merchandise, spreading their brand via word of mouth and social media posts and
where possible, purchasing physical copies of their music. 77 More than 200 million
people use streaming services, allowing artists to garner a following much quicker and
easier than via traditional means.78

Conclusion
Over the past decade, the music industry has undergone rapid digitalisation, with
Spotify, Apple Music, Pandora Radio and other major streaming platforms replacing
older forms of music consumption such as downloading. The research question that has
been explored was: how has the rise in popularity of online music streaming services
financially impacted Australian artists? A song recording usually consists of three
separate forms of copyright in which streaming services must obtain licenses to gain the
rights to communicate to the public via streaming. Royalties are calculated by a ‘pro
rata’ system which pays rights holders at a certain rate per stream. Some artists argue
that their talent gets severely underpaid and have fought for higher royalties and policy
changes through union and advocacy groups. Music streaming services have
responded to criticism about the fairness of their payment models by arguing that the
cheaper and more convenient access to music is reducing consumer piracy rates. They
therefore claim that their services are ‘revenue neutral’ along with being tools for
promotion and exposure. Contributing to this decline in piracy are stronger copyright
protection laws which in turn have increased the number of monthly subscribers and

76
The Economist, “Having Rescued Recorded Music, Spotify May Upend the Industry Again,” The
Economist (Blog Post, 2018) <https://www.economist.com/business/2018/01/11/having-rescued-
recorded-music-spotify-may-upend-the-industry-again>
77
Ibid.
78
Emma Clark Gratton, “You Can Make Money on Spotify,” ArtsHub Australia (Report, 2017)
<https://www.artshub.com.au/news-article/features/audience-development/emma-clark-gratton/you-can-
make-money-on-spotify-253079>
payment to artists. Overall, unless policy change occurs, Australian artists are likely to
continue to be dissatisfied with the remuneration for their work.