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ZAMCOPS Bought Audio Fingerprinting to Fix Zambian Royalties. Its Own Filings Say the Problem Was Never Measurement.

On 13 February 2025 the Zambia Music Copyright Protection Society, the only body licensed to collect performing, mechanical and synchronisation royalties in Zambia, announced that it had engaged ACRCloud to fingerprint what Zambian radio plays. No master recording moved. No publishing right moved. ACRCloud acquired no interest in a single Zambian song. What ZAMCOPS bought was evidence: an automatic content recognition system that matches broadcast audio against a reference database the vendor says holds more than 150 million tracks, so the society can say precisely which works were played and therefore who should be paid.

Two months later, ZAMCOPS’s own general manager said fewer than 15 of the country’s more than 150 radio stations held a licence at all.

That pairing of dates is the story. ZAMCOPS has bought a very good answer to a question that was never the binding constraint.

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What ZAMCOPS actually bought, and what it did not#

The distinction matters because it is routinely blurred. ACRCloud does not own, administer, distribute or license Zambian music. It sells audio fingerprinting, the technology behind song identification apps, as an API. Here it supplies ZAMCOPS with identification data about broadcast streams. The rights sit elsewhere: ZAMCOPS holds them by assignment from its members, who are issued what its own 2022 annual report calls a “letter of membership/Deed of assignment” on registering, against a one-off K350 fee for composers, authors and groups, or a K1,000 annual subscription for publishers.

Both parties scope the engagement to radio and only radio. The announcement says monitoring runs “across various Radio stations”. ZAMCOPS’s website carries a footer credit on every page reading “Radio Broadcast Monitoring by” above the ACR logo, linked to the vendor, with the logo file uploaded to the society’s own server in February 2025. Television, bars, hotels, gyms, casinos, malls and digital services, all of which appear in ZAMCOPS’s published licensing categories, are not named by either party as in scope.

Neither party has disclosed what the engagement costs, how long it runs, how many stations it covers, or when it went live. No figure appears in the announcement, on either company’s website, or in any ZAMCOPS annual report.

Why measurement was never the binding constraint#

A fingerprinting system tells you, to the second, what an unlicensed radio station played. It does not make that station take out a licence, and it does not make a station that owes money pay it.

ZAMCOPS’s own record is clear about where the money is stuck. In April 2025, two months after the announcement, its general manager said radio stations top the list of copyright violators despite being the biggest users of music, and that of more than 150 radio stations in the country, fewer than 15 were compliant. Measurement does not move that number. Licensing and enforcement do.

Then there is the state broadcaster. ZAMCOPS won a High Court action against the Zambia National Broadcasting Corporation over unpaid royalties, and its 2022 annual report records the outcome with care: ZNBC “has since paid all monies owed to ZAMCOPS up to 2013”, with amounts owed “from 2014 to date” still the subject of engagement with ZNBC’s administration, the Ministry of Information and the Ministry of Commerce, Trade and Industry. As of the society’s most recent published report, the national broadcaster had settled up to 2013 and no further. Fingerprinting the 2026 schedule does not collect the 2014 invoice.

The money ZAMCOPS has, against the money it owes#

ZAMCOPS’s last published audited accounts, for the year ended 31 March 2022, record revenue of K799,023, down from K853,584. Public performance tariffs brought in K763,411. Mechanical rights brought in K212 for the entire year. Operating expenses were K1,139,856, producing an operating loss of K77,600.

The balance sheet is where the artists appear. Royalties payable to members stood at K3,182,293. Trade and other receivables, money licensees owed and had not paid, stood at K3,225,290. Cash and cash equivalents stood at K96,209.

Read those three together. The society owed its members roughly K3.18m, held roughly K96,000 in the bank, and was owed roughly K3.23m by the businesses playing the music. In the same year it distributed K884,773 to members, which it attributes directly to the ZNBC action. Its two other published distribution totals: K447,177 for 2017 and K557,597 for 2018.

Against a society of that size, the relevant question about any vendor engagement is what it costs relative to K799,023 of revenue. Neither party will say.

The monitoring system has been imminent since 2018#

ACRCloud is not the first time ZAMCOPS has told members monitoring is coming. Its 2019 annual report states that “the music monitoring system implementation has reached an advanced stage and we are hopeful that it will be rolled out soon”. Its 2020-2021 report records the chairman informing members “that ZAMCOPS is in the process of introducing the monitoring system”.

In AGM minutes published in the 2022 report, a member, Bishop Nga’mbi, asks whether the monitoring system has been introduced and how effective it is. ZAMCOPS’s recorded answer: “The monitoring system hasn’t yet been put in place as owners of our broadcasting stations and the Ministry of Information are still in discussions over the same issue.”

That is the society naming the blocker, and the blocker is not technology. It is consent from station owners and the ministry that regulates them. Nothing in the February 2025 announcement, on either party’s website, or in any Zambian reporting this desk read, records that blocker being resolved. An earlier report notes members being told “all broadcasting institutions will be compelled to produce log sheets”, an obligation nobody has enforced.

There was an earlier intermediary, and members never saw its numbers#

ZAMCOPS has signed a third-party agreement over its members’ repertoire before. The 2019 report records that notice of termination was served on two contracts, one with an entity it calls Africha and one it calls SPICE. The SPICE contract terminated on 30 September; the Africha contract, the report says, “will fully terminate with all content pulled out of the orchard by January 2020”. The 2020-2021 report, in the outgoing chairman’s valedictory, is blunter: “The infamous africha agreement was ended on 14th January 2020. A major reason for my election was my promise to see an end to this agreement and hand the music rights back to the artists.” He adds that the board “ended any other agreements that reflected this nature”.

One economic term survives into the public record. AGM minutes note that members “were informed that a 30% administrative fee will not be deducted when distributing royalties from Africha”. What ZAMCOPS received under the agreement never appears. When a member asked how much the society had received from Africha, and why the music was still online, the recorded answer was that only a member committee set up to examine the matter was mandated to provide that information, and had reported at a previous meeting. No figure appears in any annual report ZAMCOPS has published. Two of those reports also date the same termination differently: 14 January 2020 in one, 20 January 2020 in the next. Neither is corrected.

What could not be established#

ACRCloud’s legal entity, incorporation jurisdiction and ownership are absent here because they could not be established. Its about, terms, privacy and legal pages each returned the same homepage content, naming no company, company number or registered office.

Whether the system is operationally live is also not established. The footer credit shows a relationship both parties still acknowledge; it does not evidence a working deployment, and no source says any ZAMCOPS distribution has been calculated from fingerprint data. The society has published no annual report for any year after 2022, so there is no audited account of what the engagement cost or changed. In October 2025 the general manager attributed falling payouts to a different cause entirely: local airplay had dropped from 95 per cent to below 50 per cent, and “the reduction in airplay has led to a significant drop in royalties paid out to artists”. That is a claim about what stations choose to play, not about whether anyone can measure it.

What this means for artists#

If you are a Zambian songwriter signed to ZAMCOPS’s deed of assignment, accurate airplay data changes one thing: the share-out. Better measurement decides how a pool is divided. It does not decide how large the pool is. On the society’s own figures, the pool is the problem. Fewer than 15 of more than 150 radio stations held a licence. The national broadcaster had paid up to 2013. Members were owed K3.18m against K96,209 of cash.

So the test for this engagement is narrow and answerable. Does ZAMCOPS publish an annual report for a year in which fingerprint data was used, showing the licensed-station count rising and a distribution calculated from airplay rather than from whatever log sheets stations chose to hand over? Until that document exists, a Zambian artist has gained a better camera pointed at a room where most of the money was never collected.

The Africha episode supplies the second point. Zambian rights holders have already been through one intermediary arrangement whose administrative fee was 30 per cent and whose consideration to the society was never published to the membership. The question to ask of any new intermediary, technology vendor included, is not whether the technology works. It is what it costs, for how long, and whether the members whose rights are being administered will be shown the number. On this engagement, they have not been.

The pattern is regional: Malawi’s COSOMA royalty cut, Zimbabwe’s dissolved ZIMURA board, Angola’s shuttered society.

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