ANDERSON, Ms Lilia, Research and Policy Lead, Media, Entertainment and Arts Alliance [by video link] DEANER, Mr Matthew, Chief Executive Officer, Screen Producers Australia DICKINSON, Mr James, Chief Executive, Screenrights DUNCAN, Ms Jacqueline, NSW Branch President, Equity, Media, Entertainment and Arts Alliance [by video link] GAROFANO, Mr Stephen, Director of Policy, Screen Producers Australia HALL, Ms Bianca, Federal Vice-President, Media, Media, Entertainment and Arts Alliance [by video link] PORTELLI, Mr Adam, Acting Chief Executive, Media, Entertainment and Arts Alliance [by video link] STEENDAM, Mr James, Federal President, Musicians, Media, Entertainment and Arts Alliance [by video link] [10:05] CHAIR: Welcome. I understand that information on parliamentary privilege and the protection of witnesses giving evidence to this inquiry has been provided to you. I appreciate that we've got quite a full panel. I'm keen to hear a short opening statement from each of you, but can we make it quite short because I know there'll be lots of questions that the committee members will be seeking to ask. I now invite you to make an opening statement. Mr Dickinson : I thank the committee for the opportunity to speak today. I'd like to just briefly outline Screenrights's position with regard to artificial intelligence and copyright. We're a copyright collecting society representing rights holders in film, television and radio. We administer several statutory licences in Australia for the use of audiovisual content for non-profit purposes, including education and government and also for retransmission, which is a commercial purpose. In that role, we have about 5,000 members from around the world, including producers, broadcasters, writers, directors, music copyright owners and owners of artistic works. Our members are very diverse and have very diverse views on artificial intelligence and copyright. For example, our members include many large copyright owners, one of whom just gave evidence before the committee, and they have the resources and market power at different levels to negotiate directly with AI companies. They do not generally need assistance from Screenrights in the form of collective licensing. In our submission, we're focused on our smaller members who do not have that market power and are looking for help to collectivise. Through a survey we conducted of Australian members last year, two-thirds are interested in licensing or are willing to consider it, but the vast majority of those, almost 90 per cent, say that they do not have the ability to license themselves. They said in a further question that they need assistance to meet the overwhelming market power of the tech companies. For this reason, Screenrights recommends the introduction of an extended collective licensing framework into Australian copyright law. This structure, which has existed in Europe since the 1960s, based on collective bargaining, facilitates the creation of collective licences while allowing those that do not wish to participate to opt out from the scheme. Critically, the opt-out is workable as it is managed through interaction with a collecting society. In contrast, Screenrights's view is that the opt-out that I understand the tech sector propose is unworkable because our members do not have control of the terms on which their content is hosted in third-party platforms. Extended collective licensing offers a practical way forward where every copyright holder, large or small, can be fairly paid while tech companies gain legal certainty. Thank you. CHAIR: Thanks very much. I'm just conscious of time. I expect we have opening statements from everyone. Could we shorten them and potentially also provide your full opening statements to the committee on the written record? Mr Deaner : I'm happy to do so. As a quick summary, Screen Producers Australia has 800-plus businesses and is the peak trade body for screen production and screen professionals, in the sense that they're paid workers in that space. Screen production is essentially about the creation, adaption and exploitation of intellectual property. So we're working with all the component parts of the industry to do that, from, obviously, the writers to all the creators and all of the commissioners, and we're transacting in intellectual property. The producer is effectively the CEO of that production, but, in order to get to realisation, there's a great sharing of the copyright based on the different creative and financial rights that are allocated. So it's quite a complicated web of financial and creative outcomes that everyone's achieving. I think that the challenge within our membership is a bit like what James has discussed, which is that we have some very large businesses that do have some market leverage—they may be internationally backed and they have back catalogues—but there are also many small creators and small businesses that are part of that membership and that do not have that purchase and leverage. To wrap it all together, we think it's critical that the consent provided by members to the treatment of their copyright is meaningful; that the compensation they receive for the use of their copyright in training, retrieval and other AI related issues is reasonable; and that the regulatory architecture which governs transparency, enforcement and penalties is workable. We've got to manage all of those outcomes out of this—everyone who's got the large basis but also the small creatives—and I think transparency is critical to making that all work. I think I might leave it there and submit our statements so that we can move forward. CHAIR: I appreciate it, Mr Deaner, thank you. Representatives from MEAA, would you like to make a short statement and potentially submit your full statement to us? Over to you. Mr Portelli : Chair and members of the committee, thank you for the opportunity for us to appear today. The MEAA represents workers across Australia's media, entertainment and creative industries, including journalists, performers, musicians, screen workers and other creative professionals. Our central message today is simple: Australia's approach to artificial intelligence must recognise the value of human creative labour and give workers a genuine right to control, and be compensated for, the use of their work. I'm sure everyone in this room and appearing today acknowledges how integral Australian arts, media and culture are in inspiring and informing our society and democracy. We know that AI is already having significant consequences throughout our industries. It is being introduced into our newsrooms and screen productions, synthetic music is competing with musicians on streaming platforms, voice artists and performers are facing digital replicas of their voices and likenesses, and it is, of course, displacing many, many jobs. It's particularly serious because creative and media workers already operate in very precarious industries. AI risks further driving down the value of their work, reducing employment opportunities and removing important pathways into creative careers. Our submission argues that the protection of copyright alone cannot solve the problem that we face. Copyright may be sufficient for media and entertainment companies to strike deals with AI companies. MEAA, to be clear, supports the maintenance of a robust and effective copyright regime. However, it was not designed to guarantee that the people who actually create the work receive fair compensation when their work is exploited through AI. Licensing arrangements between rights holders and AI companies can and do occur without creators being at the table or necessarily sharing in the benefit. That is why our first and most significant recommendation is an equitable remuneration scheme. We propose a targeted fee on AI companies across the AI technology stack. Revenue would support two things: firstly, direct payments to creative and media workers whose work contributes to AI systems; and, secondly, a cultural fund supporting Australian live entertainment, screen, music, public interest journalism and cultural activity. The committee will see from our submission that we have a number of other recommendations, including requiring transparency around the material used to train AI systems, effective take-down rights, mandating robust labelling of AI generated material, establishing enforceable protections for Indigenous cultural and intellectual property, and others. We are not arguing against technology; MEAA is arguing for a system in which technological development does not come at the expense of the people whose creativity, skill and labour help to make the technology possible and whose work is essential to Australia's cultural fabric. Recently, the Prime Minister stated: An artist's creative endeavour is their work and their property. No company should use Australian books, music, art or news to build or train AI without the artist's control. That includes the artist's control of the price and value of their work. Anything less, is theft. We wholeheartedly agree with the Prime Minister's comments and urge him to be true to his word and urge the Australian parliament and this committee to take the opportunity that we now have to build an AI framework grounded in fairness, consent, transparency and proper remuneration. I'm very happy to have with me today to assist in answering your questions not only Lilia Anderson, who is MEAA's policy and research lead, but also three creative workers, Bianca, James and Jacqui, all who are working at the coalface and have personal lived experience with AI and how it's affecting our important cultural industries. CHAIR: Thanks, Mr Portelli. We'll move to questions. I've got a question that I'd be keen to provide an opportunity for everyone here to answer. Just thinking about what is happening right now, can Australian creators seek payment for the use of their work in training activities as it's happening elsewhere? Is there any mechanism at the moment available to Australian creators? Mr Dickinson : I don't want to give legal advice, and, at any rate, I'm not a lawyer. The most important principle to recognise is that Australian copyright law only governs activities in Australia. There was a question earlier about activities under fair use in the United States. It's not relevant to Australian copyright law. But Australian creators and creative industry companies can and do seek to license, and there was the example of Microsoft and Channel 9 earlier. Licences are possible where you have a willing but not anxious buyer and a willing but anxious seller, but clearly it's not easy. The smaller you are, the harder it gets. CHAIR: Yes, which is to the point that you made in your opening statement around the capacity for smaller and individuals and to the point that Mr Portelli raised around not just rights holders but the workers themselves. Can you explain a little bit further about the proposition around how we make sure we can provide—Mr Portelli made that point around the Prime Minister's positioning that we need to create a system where creatives do have control over their content and have the capacity to be fairly compensated for it. Mr Dickinson : I think one way to consider that question is that—and this touches on a question in the previous session—there is no uncertainty about Australian copyright law at the moment. At one level, in a legal sense, they have the capacity to enforce and exercise their rights now. It's more a question of commercial power and the ability to do so. There's obviously a very clear imbalance in that market power with these large multinational corporations versus increasingly smaller organisations. Even broadcasters struggle to do that. And the other side of that equation is that those large corporations also hold all the data and the information. It's an incredibly imbalanced market, so it's very difficult. That is the short answer. CHAIR: Mr Portelli or anyone from MEAA? Mr Portelli : I'm sure some of our colleagues here could talk to their own experience accessing or otherwise copyright, but the disconnect here is between the copyright held by those licence holders and our members, the creative and media workers, because, on the vast bulk of occasions, journalists, actors, musicians and crew do not hold or receive ongoing remuneration through copyright payments. CHAIR: I appreciate our deputy chair will be joining us a bit later, so I might throw to Mr Watts. Mr WATTS: Screenrights, your white paper says: If we retain the status quo of direct licensing only, many AI developers will likely continue to use copyrighted material without permission from or payment to rightsholders. It strikes me that that's a pretty frank statement that the status quo isn't working, but the joint submission talks about there being no market failure. Mr Dickinson : Screenrights' position is, I suppose, a bit more nuanced than that of some of our colleagues, which is not to disagree with their position. I think it depends on who you are within the market. If you are a large copyright owner and you have the ability to enforce your rights, then the system works well. The majority of our members are smaller copyright owners, and for them the system does not necessarily work that well. For AI companies, clearly they have no wish to engage with those organisations in order to resolve that outcome. Mr WATTS: Okay. I want to clearly understand what the status quo is that everyone is experiencing with respect to AI training. For frontier labs that do AI training in a non-Australian jurisdiction, is anyone being paid for that now? Mr Dickinson : I can't speak to that. I don't know the answer to that question. Mr WATTS: It's an open question to all the rights holders here. Unidentified speaker: Not that I'm aware. Mr Deaner : Not that we're aware of. Mr WATTS: No-one's aware of it. The status quo doesn't sound like it's working for anyone. Mr Dickinson : I think, when you speak about the status quo and the frontier model training, it's important to recognise there is no frontier model training occurring in Australia, and we're talking about the status quo in Australian copyright law and the Australian market, as I think Ms Gilchrist referred to in the previous session. In regard to the fair use protection that the tech companies seek to rely on in the United States, it's incredibly heavily contested. I can't recall the latest number, but tens of, if not hundreds of, individual pieces of litigation have been launched by very large copyright owners. That's going to take several years to play out. And there's an expectation that'll go through multiple levels of the courts. To the extent that we say that that is not working, frankly, it's unknown even in America. Mr WATTS: But, just for Australia, there's no training being done here. The frontier labs say they won't do training here without—however you'd describe it—a change to the status quo. Under the status quo, no-one is being paid for frontier training that doesn't happen in Australia. Mr Dickinson : That is my understanding of their position. Mr WATTS: You talk about the US litigation. There have been two court rulings so far—on training on books and on general purpose models. Both of those rulings found a fair use exception permitted that training. There are lots of other pieces of litigation going on at the moment, but the position under US law at the moment is that that training is permitted under the fair use exception in the US. Mr Dickinson : I do not claim to be an expert on fair use or the litigation that's occurring. I think possibly some of the representatives in the next session would be better placed to answer that question, Mr Watts. But I know that there are other court cases in different jurisdictions, such as in Germany, which have gone the other way. There are questions that I understand have been raised in earlier hearings in terms of the way in the US the cases were introduced. I know that there have also been very large settlements. Most recently I understand Anthropic agreed to pay $1.5 billion or $1.8 billion for books. Mr WATTS: That was the case that I was referring to that explicitly said that fair use did cover it. That payment was made for infringing material that was ingested. It wasn't about the use. It was explicitly saying that, if the books were legitimately ingested, the fair use exception would have covered the training. I suppose what I'm saying is the question that we have is: are we seeking to have training happening in Australia? These labs have many places they can do the training. If it's not happening in Australia, there are many places that it can happen, and we get nothing. We can continue with that status quo, continue to get nothing and continue to get no frontier training in Australia. But it doesn't sound like that status quo works for anyone at the moment. Mr Dickinson : I think it's difficult to say because I think, again, the situation in the United States is unclear and that may settle in the opposite to the way those earlier cases have gone. And that's how the industry is generally tackling that question. And so, as to whether we should move to try to incentivise frontier model training here, I don't think it's a question of whether we want to see copyright owners remunerated here in a different way. I think there needs to be a different motivation to try to understand why we should do that. Mr WATTS: I suppose my proposition is that the status quo as a remuneration is zero, so, if we are able to leverage the training of frontier models in Australia in a way that gets us more than zero, there is potential to do a deal that is better than the status quo for Australia. Mr Dickinson : Another way to reframe the question is that, if they can continue to do it for nothing overseas, then why would they come to Australia? Mr WATTS: There are many reasons that they would want to come to Australia. They've told us that and they've said that they are willing to make payments. So what I'm trying to understand is do we want to defend a status quo that doesn't work for anyone, or do we want to explore a better scenario if it's on the table? Mr Dickinson : I can speak for Screenrights in saying that our view is that the current licensing system under Australian copyright law could be improved by the introduction of an extended collective licensing framework. That would benefit, in our view, both sides of the market transaction. By allowing copyright owners to collectivise, they maintain control of their copyright through a licensing body's opt-out mechanism, not the tech sector's preferred RTPM mechanism. At the same time, it gives certainty to the tech sector if they truly do wish to train in Australia and are genuine in their view, in their statements, that they are willing to pay a fair fee to copyright owners. Mr WATTS: There are submissions from other witnesses to this inquiry that suggest that the sensitivity from the frontier labs isn't actually making payments that ultimately end up with content creators in Australia. It's the legal description of those payments as a licence. Under US fair use law, the entering into of licence agreements has evidentiary value in their ability to make use of that fair use exemption. If there were a world where they were licence sensitive but not price sensitive—to put it as one submitter did—would you hold for a licence, or would you hold for the value going to your creators? Mr Dickinson : I struggle to respond in the hypothetical. It depends on what are the exact circumstances. A situation where the copyright owners have control of what the arrangement is, however you might describe it, and are willing but not anxious sellers that are prepared to offer their content to the extent they are at a price which they believe is fair to them is the way the system currently works and should work as opposed to an arrangement where a large foreign company, for different reasons, says, 'We're prepared to pay this amount into'—say—'a fund.' By definition, anything that they might be prepared to pay into a fund must be less than what they would have to pay under a market arrangement, or else why would they do so? Mr WATTS: Under the Prime Minister's framing, then we have control over—control and price are the key factors here. As to a legal technicality on a description of something as a licence, really, if you're getting paid at the end of the day, you have control and you have price. CHAIR: Thanks. Ms Chaney. Ms CHANEY: MEAA, firstly, you call for the introduction of mandatory reporting of all materials used to train AI. Can you explain why that's important and how it would work in practice so that it would be feasible for AI developers? Secondly, for AI generated content labelling, some experts have pushed back because they think that so much content will at least partly have AI in it that the label will become meaningless and it also may reward people who choose not to label. I'm interested in your views on labelling and mandatory reporting. Ms Anderson : In terms of the transparency requirement, the importance is that a lot of creators right now—workers, journalists—do not know if their work has or has not been used, and without any mandatory transparency or reporting there is simply no way to know. That is why the principle behind it is so important. There are precedents for transparency in the EU and, recently, in California as well. Those can be drawn on as precedents for how this could possibly work. In terms of labelling, we do understand that there are technical difficulties in doing that, but there are again precedents for bringing that about. Our submission proposes take-down measures so that, if it is obvious that a label has been manipulated, there would be a take-down process to deal with that. Ms CHANEY: In terms of the practicality of the mandatory reporting, how would that actually work in practice? I think that there's one site that says, 'Here's all the content that's been used to train this AI.' What does it actually look like? Ms Anderson : Yes, there would need to be a site that would allow for identification by creators of whether their work had been used. It would need to be detailed to that level, and it would need to include material both inside and outside Australia. It couldn't just be internally inside Australia because, as we know from the previous discussion, a lot of this training is occurring outside of Australia. Ms CHANEY: Thank you. CHAIR: Senator Cadell, do you have any questions? Senator CADELL: Yes. We've had a lot of questions about copyright, but I'm concerned about replacement—voice actors especially. We've seen radio stations use AI generated voices to read news stuff. What are we doing to protect your members? Mr Portelli : It might be worthwhile for Jacqueline, who is a voice actor, to take this on. Ms Duncan : Yes. To answer your question explicitly, I don't know what's being done to protect my voice explicitly. That's why we're here today—to seek protections. I'm a voice actor. As I said before, one of the areas of voice work I do is in commercial radio and on television. I've done over 5,000 commercial reads, probably. I don't know how to track if my voice has been taken to train anything, but I also have definitely seen my work diminish over the last 18 months or so in terms of what I've been able to earn. I have had to get a second job to earn a living, and I never gave consent for my work to be taken. So I think one area of protection is to get consent for the export of my work. When I do commercial work, I don't hold that copyright, so I don't know how I'm going to be protected. Senator CADELL: Thank you for that. There's some labelling, I think, in the EU. They mentioned an opt-out model—this is on voice—and the opt-out model in the EU being different from the one proposed in Australia. I think in the EU you have to label before an ad if AI voices are used in some jurisdictions. Is that correct? You don't know? Ms Duncan : I'm not sure. Do you know, Lilia? Ms Anderson : The only thing I would say with these proposed opt-out and consent models is that often they're about rights holders and they're not about original workers whose work is being used. I think a through line in this whole discussion is that often the rights holders' interests are being centred and the original creators, who might trade away their rights as part of their employment, are not being considered. So one of the things that we're trying to say today is that having these opt-out mechanisms or these licensing mechanisms or whatever it is that are built to essentially remunerate rights holders or allow them to opt out, don't actually serve the interests of workers, who are the ones who are being so affected, potentially, by redundancy or by the displacement that AI is bringing. Senator CADELL: I raise this, and I will be slightly pedantic and redundant. I have gone over this a few times. In the creative space, in learning, it's not as big as the coders, the news articles and the mathematical formulas in the frontier models. They don't have any established body whatsoever, as media and arts do. I gather the MEAA is looking at section 43B of the Copyright Act in Australia. Do you have a view on whether it covers the inference models now? I have concerns that, if I were a lawyer, I wouldn't be able to say to a client, 'You have rights to go and use it.' When I'm getting apps that take a song and turn it around and video clips which are purely created, they're all in the inference space. Do the MEAA or others have a view on 43B as it stands in Australian copyright law? Ms Anderson : We don't have a view on that. Again, it goes back to our view that this is the difference between workers and copyright holders. Our interest in appearing today is to represent our members, many of whom do not hold copyright. I mean, we support the copyright regime. We think that rights holders should be fairly remunerated for any licensing deals that they do. But our primary interest is in workers' interests, and those are not necessarily served through the copyright system, which is why we're arguing for something else, a copyright-plus system whereby there is some transaction between AI companies and workers that means that workers are getting some remuneration for the use of their work by these systems. Senator CADELL: I reminisce, and it is showing my age, back to an earlier briefing about Max Headroom on the ABC and how he was one of the first AI-generated characters to come out and create that space. We're seeing it become more and more life-like, realistic, not just in voice but in creation. Do we see a potential risk to creation overall, where there is no longer a need for mainstream actors or names to visually recreate these things in code rather than in personality? Ms Duncan : My Sincere apologies. I just dropped out for a second. Can I just ask what you are referring to? Senator CADELL: We joked that Max Headroom was a TV host back in the eighties or something when I was a kid. I watched that, but now it is very life-like. The difference between some of the videos we see and real life is very marginal. Voice is probably easier because you don't need that visual, so you don't need that bundle of data. But can we see a replacement? You're losing work. Can we see that right across the visual arts, right across the creative arts—in workers, not copyright? Ms Duncan : I think so. Something that I heard before was that AI labelling may reward those that choose not to use AI. I think there's actually a positive to that because AI is not creative. Humans are uniquely creative. I use my conscious mind, my unconscious mind, my training, my experience, to do a voiceover, to do an acting performance. So when that is taken to train AI along with thousands of other inputs and a recommendation, it will come up with generative AI that has not just taken the data that has been input but it has taken my training, my consciousness, my experience, my performance. I think there's a general ignorance to what generative AI takes to output something. There is no creation in that output. It is just that a company has chosen to not use an actor in a commercial because it was cheaper for them, so there should be merit to those who are still paying those whose work is on screen. Whether it be AI or not, it is creators' work that has been input to put out that performance. There needs to be clarity for people in terms of understanding that this is a human performance. CHAIR: Senator Sheldon. Senator SHELDON: One of the themes running through the submission this morning from the MEAA is that existing copyright frameworks—and you've said this in a number of answers—are designed to regulate ownership and licensing but do not ensure fair compensation for creators. I note that you've said in your submission that the copyright-plus approach is a way of potentially dealing with that sort of question. What other additional protections would this provide that are not currently provided under copyright law? I might put that to Mr Portelli. Mr Portelli : I might just ask Lilia to assist with this one. Ms Anderson : Yes, sure. As I outlined earlier, a lot of workers in the creative sector and in journalism don't own their copyright. It is part of their employment contract, let's say, that they hand that over in receiving some sort of funds for their work. For example, in the music industry, you see musicians handing over their rights over a recording in return for some payment. That means that if those rights are subsequently sold, let's say for AI licensing, there's not necessarily any funding going back to that original artist for that transfer of work. That transfer of work is allowing an AI company to potentially use that work to train a model that can do, to some extent, the work that that original artist was trained to do—to produce music—which in turn has a potential redundancy or substitution effect on that original worker. Copyright plus ensures that the original worker receives some payment, which they potentially would not under the copyright system as it is now, and in turn is compensated to some degree for the loss of that work and for the potential redundancy or substitution effects that that would have. Mr Portelli : I think that copyright plus—that form of payment along with some of the control measures in our submission around labelling, the maintenance of copyright and also Indigenous cultural and intellectual property, which we have not discussed in this hearing yet—really represents our members' bottom lines. That direct payment in the way that it has been described and the control measures that I think are necessary; the transparency, both for our members and for the Australian public; the maintenance of copyright; and finally that Indigenous cultural sovereignty piece really form the basis of our submission and the bottom line for our members. We think that would be a fair and a reasonable way to approach AI in our industries. CHAIR: Thank you very much. I appreciate we are coming up against time. I know Ms Mascarenhas and Senator Pocock both have questions. I might quickly do both of you at once and get a quick response and then potentially additional information provided to the committee on notice. If we can make it short and sharp, that'd be wonderful. Ms MASCARENHAS: I'm happy for my question to be answered on notice. It fundamentally is about jobs in each of your sectors. I think you've got some great case studies in your submission, but, fundamentally, what I'd like to understand is the impact on, let's say, headcount or the number of jobs within each of the industries—I know that we haven't seen recovery post pandemic, but I think the space is changing very quickly—and what that means for the pipeline of future creatives. That can be answered on notice unless you want to quickly add a very short answer. CHAIR: I'll go to Senator Pocock and then get a wrap-up statement. Thanks. Senator DAVID POCOCK: You can see why these AI companies are running a mile from any sort of licensing, given the court cases in the US. MEAA are proposing an equitable remuneration fund be set up. How much of any funds disbursed would remain in Australia, given we'd have to compensate copyright holders globally? Ms Anderson : I can answer the second question, but I wonder if Bianca wants to speak to the first question briefly because she has some personal experience in this area. Ms Hall : I am a journalist of more than 20 years. In that time, overall employment in newspaper publishing has collapsed, with about a 60 per cent reduction in the overall size of the workforce. It is absolutely accelerating with AI. At Nine, 30 metro masthead roles were recently made redundant, including my own, amid what management called 'extreme' AI disruption. Seven, the broadcaster, has rolled out a new AI tool called Clippy, which came in the wake of more than 150 jobs being lost, and jobs have also been cut at News Corp, where AI has been very, very heavily adopted. Ms Anderson : In terms of Senator Pocock's question, equitable remuneration has been adopted in most other countries across the globe. Australia's a missing link in that specific treaty, that obligation that I think you're referring to. We're proposing, in addition to that, a system of payment that is based on a fee that's levied across the AI stack. There are a few different things going on in our proposal, but as to the amount of money that would stay in Australia, yes, there would be some payments overseas, but this would ensure a reciprocal system that would make sure that payments would be coming back into Australia. We've seen in the past that, because of that nonreciprocity, other countries have stopped payments to Australian musicians and performers. It just ensures the reciprocity of that system and ensures that that doesn't happen in the future. CHAIR: I will call time on this session today. Thank you very much to everyone for participating and contributing. If there is some information that you've committed to bring back to us on notice, we ask that you provide it to the secretariat within two weeks..