Regulatory and funding landscape

Among the CresCine ecosystems, there are no strict legislative frameworks governing release windows comparable to the “media chronology” found in France or the statutory rules in Bulgaria. Instead, regulation in these territories is primarily indirect, functioning through public funding guidelines that incentivize or mandate specific distribution behaviors to ensure the visibility of supported works.

Ireland has the most structured requirements among the ecosystems regarding funding eligibility. Screen Ireland mandates “viable theatrical windows” for all projects receiving production funding, specifically requiring a 24-month theatrical window for feature films and a 12-month window for documentaries starting from their first festival screening. Similarly, while Lithuania does not enforce a general release schedule, the Lithuanian Film Centre imposes specific distribution criteria for funded projects; for instance, feature films must be screened in at least two cities for seven consecutive days.

Estonia also integrates distribution goals into their support schemes without setting rigid statutory windows. Minority co-production support is conditional on the film being screened in cinemas or on streaming platforms within one year of its international premiere.

Contractual standards and market practices

In the absence of a strict legislative framework, the standard practice across Portugal, Croatia, Flanders in Belgium, and the wider commercial sectors of Denmark, Estonia, and Lithuania is for release windows to be defined contractually on a case-by-case basis. This “free market” approach means that holdback periods are negotiated between rights holders, exhibitors and platforms, often influenced by international release strategies.

In Portugal, where distributors typically hold all rights, there are no mandatory windows, but market averages suggest a three-month holdback for physical and transactional video-on-demand (TVOD) releases, extending to six months for pay-TV and twelve months for subscription VOD (SVOD). A similar pattern exists in Lithuania, where transactional online distribution typically begins two months after the theatrical run, while free TV broadcasting waits up to 24 months. However, flexibility is key; in Lithuania, foreign releases often maintain shorter windows compared to local films, which may enjoy longer exclusivity.

Denmark operates under an industry agreement dating back to 2011 that established a standard four-month holdback for DVD and VOD. While this remains the current practice for major releases, the system allows for exceptions, such as “discount days” that distributors can use to shorten windows for specific titles. 

In Flanders, releases generally secure shorter exclusivity periods, averaging 53 days compared to 82 days for non-Flemish films, with second-circuit screenings frequently beginning around the six-week mark. Nationally, the common contractual pattern sees DVD, Blu-ray, and digital purchase (EST/DTO) releases three to four months after the theatrical run, while the key secondary window, SVOD, varies widely from seven to thirty-six months based on specific title arrangements, and television broadcasters are legally required to respect these contractually agreed broadcast periods.

To adapt to the streaming era and changing audience habits, several of these markets are experimenting with more flexible models. The Danish Film Agreement (2024–2027), a four-year cross-party political agreement that sets the policy framework, priorities, targets, and public funding envelope for Danish film,  introduces a formal condition requiring producers, distributors, or cinema partners to ensure that films with low box-office performance are made available to the public more quickly on digital platforms, including television.

In Flanders, hybrid release models, such as the YouTube Ciné-Club initiative, where the documentary The Toughest Race on Earth by Belgian YouTuber Average Rob was released in cinemas for limited runs and then made available online almost immediately, bypassed traditional, lengthy exclusivity periods. While such strategies remain relatively recent and not yet the dominant industry norm, they signal a growing experimentation with alternative circulation models. Similar developments can be observed in other European contexts, including France, as well as in recent cases such as Iron Lung (2024) (relevant as film driven by creator economies and platform-native production).

State of play in the EU

Strict legislative measures defining release windows are rare within the EU, with only France and Bulgaria enforcing such frameworks through national statutes. France operates under a highly structured system known as “media chronology,” which is deeply tied to the preservation of cultural heritage and the financing of local production. This framework was recently modernized to accommodate evolving viewing habits; notably, the window for subscription video-on-demand (SVOD) platforms was shortened from 36 months to 15–17 months for services that sign agreements to invest in local filmmaking. In contrast, Bulgaria utilizes a simpler statutory framework, mandating a three-month window for video and digital platforms and a six-month window for free television following a theatrical release, although exceptions can be made if specified in distribution contracts.

A significant number of EU countries regulate release windows indirectly by linking them to eligibility for public funding. In these territories, adherence to specific holdback periods is a mandatory condition for films receiving state aid. Germany and Austria exemplify this model, where funding guidelines set standard windows—typically six months for video and VOD—but allow for reductions in exceptional cases. For instance, German regulations were recently adjusted to allow a shortened four-month window for funded films to provide greater flexibility. Similarly, Italy mandates a 105-day theatrical window for all films seeking tax credits or public support, a rule that was temporarily reduced during the pandemic but later restored to protect the theatrical sector. 

In the majority of EU member states, including Spain, the Netherlands, Belgium, and Denmark, release windows are determined through contractual agreements or industry consensus rather than legislation. In Spain, while the traditional window has been around 112 days, recent market pressures have led to drastic reductions, with some releases moving to platforms in as few as 30 to 45 days. Other countries like Poland, Sweden, and Slovakia rely on informal industry agreements; for example, Poland operates with a guideline of 75 days between cinema and online distribution, though distributors often shorten this to 45 days. In these “no measures” environments, the timeline is largely dictated by the commercial leverage of distributors and global streaming strategies.

The pressure to adapt to the digital technologies and on-demand viewing has spurred innovative policy changes and hybrid release models. Germany has introduced “force majeure” provisions allowing for online premieres when theatrical release is impossible, alongside faster tracks for films with limited commercial potential. The market is also witnessing the disruption of traditional chronologies by new content forms; in France, the documentary Kaizen by YouTuber Inoxtag was released in cinemas and made available online almost immediately, sparking debate about the relevance of existing window regulations.

The French system of film distribution and release windows has been significantly revised since the emergence of SVOD platforms. The length of the SVOD window was reduced from 36 months to 15–17 months. A new framework for release window agreements was revised in January 2022 and adopted by the French industry with the exception of Disney and Amazon (Cabrera et al., 2023). 

Videograms for sale or rental may be released four months after theatrical release, with possible reductions of up to four weeks. Pay-per-view on-demand services follow the same timing, with promotional periods beginning no earlier than three weeks before the window and ending three weeks prior to pay-TV release (Légifrance, 2025).  

Pay-TV cinema services can exploit films in a first window after nine months, or six months under agreements with professional organisations, with exclusivity limited to eight months or six months for the shorter period. Second-window exploitation begins after 17 or 15 months depending on agreements, with exclusivity not exceeding seven months (Légifrance, 2025).

Subscription-based SVOD services may release films after 17 months, or 15 months for works under professional organisation agreements, with minimum windows of six months for negotiated exceptions. Exploitation may not exceed 22 months if free-to-air or other pay-TV services are involved, with co-exploitation agreements allowing specific unavailability periods for high-cost productions or SVOD-produced works (Légifrance, 2025). Lower-budget works follow standard timing rules, with exclusivity capped at five months for first windows and seven months for second windows (Légifrance, 2025).

Free-to-air and non-cinema pay-TV services may exploit films after 22 months (or 19 months for works not acquired in second windows), with exclusivity up to 14 months, and may negotiate co-exploitation with SVOD services. Free on-demand services may release films 36 months after theatrical release (Légifrance, 2025).

Documentaries and low-budget fiction works (with a maximum of €1.5 million budget) may be released on digital platforms 12 months after theatrical release if rights offer within a 22-month window have not resulted in prior acquisition. Disputes over these exemptions are subject to conciliation by the Film Mediator (Légifrance, 2025).

Under the current system in France, theatrical release remains the starting point of the media chronology, with a standard cinema exclusivity window of four months, reducible to three months if initial admissions are under 100,000. Netflix may stream films 15 months after theatrical release, while services not signing the agreement must wait 17 months (Cabrera et al., 2023). Disney+ has negotiated a shorter 9-month window for films and French productions, with a commitment to invest in French cinema (Numerama, 2024). 

The case of YouTuber Inoxtag’s documentary Kaizen: 1 year to climb Everest! illustrates the tensions arising when digital release closely follows theatrical exhibition, generating breaches of media chronology and potential administrative sanctions. The documentary, released in French cinemas on 13 September 2024 and on YouTube the following day, achieved exceptional reach, drawing more than 340,000 cinema admissions and over 38 million online views by November 2024. TF1 later acquired the rights, broadcasting it on 8 October and offering it free on TF1+ from 28 September. However, the success of the documentary was nuanced by a controversy, as the Centre national du cinéma et de l’image animée (CNC) determined that the TF1 broadcast of Kaizen violated the established media chronology. Although national rules normally prevent works intended for YouTube from obtaining general theatrical release, an exceptional screening certificate can authorise up to 500 screenings over two days within a single week. 

Kaizen was reported to have reached around 800 screenings, exceeding this limit. The distributor MK2 stated that only 350 screenings were planned, while some cinemas reportedly added showings without consultation. Exceeding the authorised cap means the film should have requested a standard screening certificate. Under the Code on Cinema and Moving Images, unauthorised exploitation can lead to fines of €45,000 and administrative sanctions for infringement of release windows, particularly as the rights were sold to both YouTube and TF1. 

Several observers and specialised media outlets have described the situation as proof that the rules regarding release windows in France are obsolete. (see European Audiovisual Observatory, 2024; Lessurligneurs, 2024). 

State of play in the CresCine markets 

Flanders

In Flanders, release windows are determined on a contractual, case-by-case basis between rights holders and distributors. There is no statutory media chronology, leaving flexibility to adapt to market trends and negotiation outcomes (Cabrera et al., 2023).

The typical release pattern in Flanders generally mirrors that of the Netherlands, particularly for Dutch-language films, while French-language titles released in Belgium tend to follow French release trends. However, distributors retain discretion to adjust windows depending on the title’s profile and target audience (Cabrera et al., 2023).

At the national level, in the absence of binding rules, release windows for Belgian films tend to follow these broad patterns: DVD, Blu-ray, and EST/DTO releases occur three to four months after theatrical release; TVOD follows a similar window; pay-TV access generally opens between seven and twelve months; free-TV between nineteen and thirty months; and SVOD between seven and thirty-six months, depending on contractual terms and title-specific arrangements (Cabrera et al., 2019).

Recent industry-led shifts have brought new forms of release. For example, in 2025, YouTube launched its “Ciné-Club” initiative in Belgium, following its French debut and the release of the documentary Kaizen by YouTuber Inoxtag. The project premiered the documentary The Toughest Race on Earth by Belgian YouTuber Average Rob, attracting over 7,000 viewers with 25 screenings across nine Flemish cities. The initiative, in collaboration with mk2 cinemas, exemplifies how digital-native content can successfully integrate into traditional theatrical circuits, suggesting potential hybrid models for future distribution (mk2 Pro, 2025; Average Rob, 2025).

Croatia

In Croatia, the release and distribution of audiovisual works operate primarily on a contractual basis, with parties determining conditions individually for each project (Cabrera et al., 2023). At national level, eligibility for production support is not linked to specific performance requirements: there are no obligations regarding theatrical release, visibility, distribution, or release windows for a work to qualify for funding (European Audiovisual Observatory, 2019).

Furthermore, the regulatory framework stipulates that audiovisual media service providers may only transmit audiovisual works within the periods agreed contractually with rights holders, as set out in Article 16 of the Electronic Media Act (Zakon.hr, 2022).

Denmark

In Denmark, release windows are determined contractually. Online distribution largely mirrors the release patterns of physical formats, with distributors typically distinguishing between permanent-access and time-limited online models. For major titles, permanent-access releases may precede physical formats by up to ten days. Certain flexibilities exist, including approximately forty “discount days” per distributor that may be used to shorten windows, as well as individually negotiated arrangements for films with very limited circulation or for distributors operating outside the national distributors’ association. These practices are not linked to public funding and apply equally across domestic, European, and US works. No overarching agreement governs these timelines; instead, they are established independently for each film (Cabrera et al., 2023).

Denmark also applies windowing rules stemming from a 2011 agreement between the Danish Cinema Association and the Association of Danish Film Distributors. Under this arrangement, Danish feature films released in cinemas must observe a four-month holdback before availability on DVD or VOD, and a twelve-month interval before appearing on Danish television. Typical release patterns include DVD/Blu-ray at four months, pay-TV at twelve months, and free-to-air television at twenty-four months following theatrical release (Nordisk Film, cited in Cabrera et al., 2019). As a condition under the Danish Film Agreement 2024‑2027, the producer of a film, together with its distributor or cinema partner, must ensure that lower-performing titles can be made available to the public more quickly on digital platforms, including television stations. Moreover, a negotiation mechanism involving the Danish Film Institute, the Producers’ Association, DR, and TV 2 aims to establish rights arrangements that allow films to appear quickly on television while safeguarding producers’ interests. If no agreement is reached, the matter is referred to the conciliation circle (Danish Film Institute, 2023). 

A 2018 report by the Danish Film Institute highlighted the need for greater flexibility in release windows, particularly given rapid shifts in audience behaviour and the prominence of digital distribution. The report points out that 93% of cinema admissions occur within the first six weeks of release, with smaller films often screening for only two to four weeks. Consequently, the four-month holdback is considered disproportionately long for titles that disappear from cinemas well before their digital availability. The report proposes a differentiated model comprising four strands: general cinema distribution with a four-month window for high-potential films; a “Fast Track” of six to eight weeks for films with fewer than 10,000 admissions; “Event visioning” for highly niche films, allowing availability within ten days on TVOD and then SVOD services; and an “Emergency Track” enabling poor-performing films to shift quickly to digital platforms with a hold-back of six to eight weeks after the premiere (Cabrera et al., 2019).

The Danish Film Institute emphasises the need to strengthen cinema as a distribution platform while maximising Danish films’ availability in subsequent windows on television and streaming, ensuring both broad reach and financial return. Given that around 90% of tickets for a Danish film are sold within the first 42 days, rapid progression to digital and TV platforms is crucial to capitalise on the film’s topicality, marketing, and media attention from its theatrical release. Before the COVID‑19 lockdowns, the average hold-back between cinema and digital release exceeded four months, but by 2022 this had reduced to under three months. To avoid long exclusivity periods and unused windows, a differentiated hold-back strategy is recommended. Under this model, normal cinema releases have a 75-day window with digital availability required within 100 days, shorter planned windows allow 45 days in cinemas and digital release after 75 days, and event windows range from 0 to 21 days, with films moving immediately to the next window after the event (Danish Film Institute, 2023).

Estonia

In Estonia, release windows are decided by contractual agreement, with rights holders and distributors negotiating timelines on a film-by-film basis. This flexible approach also extends to online exploitation, where shorter windows for digital distribution may be agreed case by case, (Cabrera et al., 2023). In a structurally small ecosystem such as Estonia, flexibility has become institutionalised as a shared industry norm, allowing stakeholders to adapt windowing strategies pragmatically in order to preserve the operability of the national audiovisual ecosystem.

Public funding plays a role in shaping certain obligations for films produced with Estonian support, particularly in international minority co-productions. Projects supported under this scheme must be screened in Estonia, either in cinemas or on streaming platforms, within one year of their international premiere, and must be made available in Estonian or with Estonian subtitles (Estonian Film Institute, n.d.). 

Additional obligations include organising a domestic premiere within one year of project completion, ensuring television broadcast within two years, and delivering archival copies to the National Archives, including the source materials of the film, the subtitle file and the caption translation. Recipients must also provide annual reports on the film’s international distribution and participation in festivals within the first three years following the international premiere, except in the case of minority co-production films. They must also ensure equal access to all qualifying cinemas where distribution support is involved (Riigi Teataja, 2024). 

Ireland

Release windows in Ireland are primarily determined by contractual agreements. Screen Ireland expects all projects, particularly those with broadcaster involvement, to maintain viable theatrical windows. Documentaries must typically allow a minimum twelve-month window from the date of the first festival screening, while feature films are expected to observe a twenty-four-month theatrical window from their initial theatrical release.

Distribution patterns show that home entertainment and digital release windows are agreed contractually, and in practice there is no distinction between local, European, or U.S. content. Screen Ireland supports both Irish distributors and producers through distribution and exhibition funding, helping films secure theatrical releases in Ireland (including Northern Ireland) when commercial distribution is otherwise limited, thereby enhancing audience reach.

Legally, television and on-demand service providers must respect the periods agreed with rights holders, ensuring that broadcast and streaming windows align with negotiated release schedules (Coimisiún na Meán, 2024). 

Lithuania

In Lithuania, film release windows are determined contractually, allowing parties to negotiate schedules on a case-by-case basis. Typical release practices indicate a staggered approach across platforms: DVD/Blu-ray releases occur 3–6 months after cinema screenings, transactional online distribution (EST/TVOD) two months after the cinema run, pay-per-view after nine months, pay-TV after twelve months, and free-to-air broadcasting around 24 months. Foreign films generally maintain shorter windows, whereas dubbed animations and local productions may take longer (up to 4–6 months) (Cabrera et al., 2023). 

Legally, audiovisual media service providers must respect the broadcast periods agreed with rights holders, ensuring that transmission schedules align with contractual arrangements (Seimas of the Republic of Lithuania, 2021).

State funding for film production does not impose mandatory requirements regarding theatrical visibility or performance on any of the different release windows, with two exceptions: TV creative documentaries must have a TV-distribution deal and animation series projects must have a TV or VOD distribution deal (European Audiovisual Observatory, 2019). Funded films must be completed within two years from the end of the funding period, and the premiere must occur in Lithuania within three years, subject to extensions in the case of emergency or quarantine restrictions. Following the premiere, feature films are required to be distributed nationally within one year. Specific exhibition obligations exist depending on film type: feature and animated films must be shown in cinemas or cinema halls for at least seven consecutive days in two Lithuanian cities. Minority co-productions and documentaries must be shown in Lithuania for at least five consecutive days in two cities or once in five cities. Interactive films must be made available to viewers in Lithuania for a minimum of seven days within a thirty-day period or at least thirty consecutive days via video-on-demand platforms. Multi-part films are required to be accessible to Lithuanian audiences at least once in a thirty-day period on video-on-demand applications (Lithuanian Film Centre, 2025). 

Portugal

In Portugal, release windows are determined contractually on a case-by-case basis, with no statutory rules governing the sequencing of film exploitation. Average timelines indicate that physical formats such as DVD and Blu-ray are typically released three months after theatrical exhibition. Transactional online distribution (EST/TVOD) follows a similar three-month window, while pay-per-view services generally access titles after four months. Pay-TV windows tend to open around six months post-release, and SVOD and free-to-air television usually acquire rights after approximately twelve months (Cabrera et al., 2023).

These timelines remain largely flexible, as distributors in Portugal commonly acquire “all rights”, enabling them to negotiate release windows directly without mandatory regulatory constraints beyond the contractual holdbacks agreed with rightsholders. The figures provided reflect average industry practice and may vary significantly across titles. Windows may also be shortened through negotiated agreements between rightsholders and television or DVD distributors, particularly when broadcasters act as co-producers (Cabrera et al., 2023).

The absence of mandatory release windows in Portugal is echoed in the framework of the national Tax Incentive for Film Production. Although the measure does not define windowing rules, it requires producers seeking final recognition to provide distribution agreements, where available, indicating the planned premiere date, as well as any broadcast or editing agreements. Producers must also deliver two copies of the final version of the film prepared for theatrical exhibition. These requirements ensure that projects supported by the incentive are distribution-ready upon completion, aligning with the flexible, market-driven approach to release chronology (Institute of Cinema and Audiovisual, 2017).