COSOMA’s own disclosed breakdown of the Malawian Blank Media Levy it collected sums to K 2,400,000,000, not the K 3,000,000,000 it says it took in. A further 20.0 per cent cut from the rights holders’ share, which Malawi’s sole statutory collecting society describes two different ways in the same reporting window, leaves K 1,440,000,000, or 48.0 per cent of the amount collected, as the only figure this desk can trace all the way to a payout.
The breakdown comes from COSOMA’s own account, given at a 3 August 2026 Lilongwe meeting with two rights-holder companies and reported independently by four Malawian outlets: Times of Malawi, The Maravi Post, Malawi24 and Nation Online. Every figure below is a number COSOMA itself disclosed, not an estimate this desk has made.
| # | Line item | Amount, MWK | Share of K3bn collected, % |
|---|---|---|---|
| 1 | Total Blank Media Levy collected, year reported | 3bn | 100 |
| 2 | To Malawi Revenue Authority, stated administration fee | 150m | 5 |
| 3 | To government, via Ministry of Finance | 150m | 5 |
| 4 | To the Copyright Fund | 300m | 10 |
| 5 | Earmarked for rights holders, before further deduction | 1.8bn | 60 |
| 6 | Sum of the four named allocations above | 2.4bn | 80 |
| 7 | Collected total minus the four named allocations (unaccounted) | 600m | 20 |
| 8 | Further 20pct deduction COSOMA applies to the rights-holder share | 360m | 12 |
| 9 | Net remaining for rights holders after that further deduction | 1.44bn | 48 |
Source: Four Malawian trade and news outlets reporting the same 3 August 2026 Lilongwe meeting between COSOMA and two rights-holder companies: Times of Malawi, The Maravi Post, Malawi24 and Nation Online, all confirmed live (HTTP 200) on 3 November 2026., retrieved 3 Nov 2026 · download the data
The Blank Media Levy is a statutory remuneration right COSOMA has administered in Malawi since 2011, a fee on blank recording media such as CDs and DVDs, meant to compensate musicians, filmmakers and writers for private copying. It is not a licensing or ownership transaction. Two companies, Akometsi Limited and Madness Entertainment, represented by lawyers Henry Mvula and Ntchindi Chiyamwaka, pushed COSOMA on how it was dividing the money at a nearly four-hour meeting on 3 August 2026, after an earlier attempt on 30 July went unanswered while COSOMA’s executive director, Dora Makwinja, was in Blantyre on other duties.
COSOMA’s stated four-way split of the K 3,000,000,000 collected runs K 150,000,000 (5.0 per cent) to the Malawi Revenue Authority as an administration fee, K 150,000,000 (5.0 per cent) to government through the Ministry of Finance, K 300,000,000 (10.0 per cent) to the Copyright Fund, and K 1,800,000,000 (60.0 per cent) earmarked for rights holders. Those four figures sum to K 2,400,000,000, 80.0 per cent of the stated collection. No outlet this desk checked, and no COSOMA statement this desk could find, accounts for the remaining K 600,000,000.
A separate 20.0 per cent deduction then comes out of the rights holders’ K 1,800,000,000 share before any artist sees it, K 360,000,000. Here the reporting splits. Malawi24 and The Maravi Post carry COSOMA’s account that this is withholding tax passed to the Malawi Revenue Authority, the product of what COSOMA called a labelling “system error” on individual royalty statements. Times of Malawi, in the same reporting window, quotes Makwinja herself describing the identical structure differently: “Sixty [per cent] is distributed to rights holders and 20 per cent is what comes to Cosoma for the management and administration.” That is COSOMA’s own chief executive, on the record, calling the 20.0 per cent COSOMA’s management and administration take, not tax forwarded to a tax authority. No source read reconciles her quote with the “system error, it’s actually tax” account reported alongside it.
Run both disclosed deductions through in sequence and K 1,440,000,000, 48.0 per cent of what COSOMA says it collected, is the figure this desk can trace as reaching rights holders. That matches, independently, what one of the two companies in the dispute itself calculated from the same numbers.
What would have to be true for this to be wrong#
This is COSOMA’s own disclosed breakdown of one levy in one reporting year, not a sample this desk built across many rows, so the leave-one-out test this desk runs on multi-row panels does not test the same thing here. Running it anyway shows why: because rows 6 to 9 are arithmetic performed on rows 1 to 5, dropping the largest row changes the column total mechanically rather than testing whether any single, independent data point is driving the finding.
| # | Scenario | Rows | Total | Change in total, % |
|---|---|---|---|---|
| 1 | All rows | 9 | 10.2bn | 0 |
| 2 | Excluding the top 1 (Total Blank Media Levy collected, year reported) | 8 | 7.2bn | -29.41 |
| 3 | Excluding the top 3 (Total Blank Media Levy collected, year reported, Sum of the…) | 6 | 3bn | -70.59 |
| 4 | Excluding the top 5 (Total Blank Media Levy collected, year reported, Sum of the…) | 4 | 960m | -90.59 |
Source: Recomputed from cosoma-blank-media-levy-breakdown-2026, retrieved 3 Nov 2026 · download the data
The real uncertainty is not statistical, it is definitional. If the 20.0 per cent “administration fee” COSOMA described to the Malawi Revenue Authority is the same 20.0 per cent that is missing from the four-way breakdown, counted once rather than twice, then the four named allocations already account for the full K 3,000,000,000 and rights holders’ K 1,800,000,000, 60.0 per cent, stands without the further K 360,000,000 cut. If it is Makwinja’s “management and administration” characterisation that is correct and it is a separate, additional deduction on top of an unexplained K 600,000,000 gap, rights holders are left with K 1,440,000,000, 48.0 per cent. This desk could not find a COSOMA source that settles which reading is correct: COSOMA’s own site, cosoma.mw, returned a bot-wall response on every path checked on 3 November 2026, and Akometsi Limited’s site returned a rate-limited response on every attempt in the same window.
Underneath the fee-label dispute sits a longer-running disagreement this desk cannot price: COSOMA has told rights holders that Blank Media Levy distribution is based entirely on data from licensed CD and DVD burning centres, not on streaming or digital consumption, and that its own membership rejected a move to digital-consumption data at an annual general meeting. That dispute determines who inside the rights-holder pool gets paid from the K 1,440,000,000 to K 1,800,000,000 range above; it does not change the size of the pool itself, which is the subject of this piece.
For a Malawian artist or rights holder waiting on a COSOMA payout, the practical instruction is not to take either percentage on trust. Ask COSOMA in writing which of its two accounts of the 20.0 per cent cut applies to your specific statement, and ask for the K 600,000,000 gap between what it says it collected and what its own four-way breakdown names to be itemised before signing off on a distribution. A collecting society that gives two contradictory on-record explanations for the same deduction in the same week has not yet earned the benefit of the doubt on the number it has not explained at all.
