Music Licensing for Cruise Ships in Europe: what GEMA, SACEM, SUISA, PRS & Other PROs Require

Introduction
Playing music on board a cruise ship — in restaurants, lounges, pools, spas, cabins, shops, or theatres — is legally considered a public performance.
Across Europe (Germany, France, Switzerland, the UK, Benelux, Nordics, Mediterranean countries, etc.), this activity requires a licence from national Performing Rights Organisations (PROs) such as GEMA, SACEM, SUISA, PRS for Music, PPL PRS, BUMA/STEMRA, and others.
This article summarises how major European PROs regulate music use on cruise ships, how tariffs are calculated, which rights must be cleared, and what cruise ship operators must consider to remain compliant.
1. Why Cruise Ships Must Pay Music Royalties in Europe
Across Europe, copyright law classifies music played in a business or public environment as a public performance.
A cruise ship is viewed as a commercial multi-venue environment, similar to hotels, restaurants, bars, shops, spas, and entertainment venues on land.
Official guidance confirms this across several countries:
-
Germany (GEMA): Any public or commercial use of copyrighted music requires a licence.
https://www.gema.de/de/die-gema/das-wichtigste-zu-den-gema-gebuehren -
France (SACEM): Any establishment that plays music for guests or customers must pay royalties unless using completely royalty-free music.
https://entreprendre.service-public.fr/vosdroits/F3094 -
Switzerland (SUISA): Background music in businesses, guest areas, cabins, and in passenger transport requires a licence under tariffs such as CT 3a and CT 3b.
https://www.suisa.ch/en/Kunden/Hintergrundmusik.html -
United Kingdom (PRS / PPL PRS): A licence is required for recorded or live music played in public or commercial settings, including hospitality and public transport.
https://www.gov.uk/licence-to-play-live-or-recorded-music
Therefore, cruise ship operators require proper PRO licensing when playing music of any form.
2. Two Layers of Rights Cruise Ships Must Clear
Europe divides music rights into two legal categories:
2.1. Performing Rights (Authors/Composers/Publishers)
Handled by organisations such as:
-
GEMA (Germany)
-
SACEM (France)
-
SUISA (Switzerland)
-
PRS for Music (UK)
-
BUMA/STEMRA (Netherlands)
-
SGAE, SIAE, AKM, etc.
2.2. Neighbouring Rights (Performers/Record Labels/Producers)
Handled by:
-
GVL (Germany)
-
SPRE / SCPP / SPPF (France)
-
SWISSPERFORM (Switzerland)
-
PPL (UK)
-
SENA (Netherlands)
Many countries bundle these into one licence for simplicity:
-
Germany: GEMA often collects on behalf of GVL in public-performance contexts.
-
UK: PRS for Music and PPL operate PPL PRS Ltd offering TheMusicLicence.
-
Switzerland: SUISA and SWISSPERFORM jointly manage background music via common tariffs.
A cruise ship operating in Europe must therefore obtain a public-performance licence through the relevant PRO(s).
3. How PROs Categorise Music Use on Cruise Ships
Cruise ships are treated as clusters of commercial venues, including:
-
Restaurants and cafés
-
Bars, lounges, and pool decks
-
Retail stores
-
Spas and fitness centres
-
Casinos
-
Cabins with TV/radio
-
Theatres, cinemas, and show lounges
-
Reception and lobby areas
This mirrors how PROs classify hotels, resorts, restaurants, and passenger-transport environments on land.
Examples:
-
SUISA’s CT 3a and CT 3b specifically cover background music in business premises and background music in passenger transport.
-
PRS for Music includes “Cruise Ships Background Music” in its recognised usage categories through distribution codes.
-
The UK government explicitly lists public transport among environments requiring music licences.
Cruise ship operators therefore fall under standard public-performance rules in every European market they serve.
4. How Fees Are Calculated Onboard
Although every PRO uses its own tariff structure, cruise ship licensing usually depends on:
4.1. Audible Surface Area or Venue Size
-
SUISA CT 3a uses the sum of all areas where music is audible.
-
GEMA and SACEM link fees to surface area, seating capacity, or venue type.
-
UK tariffs reference audible square metres depending on the type of premises.
4.2. Types of Music Use
-
Background playlists
-
TV and radio reception
-
Live bands and musicians
-
Theatre shows
-
DJ events or dance events
-
Pre-recorded announcements containing music
4.3. Operational Days and Seasonality
Many PROs allow seasonal or partial-year licensing if a ship operates only part of the year.
4.4. Number and Type of Music Zones
Cruise operators are often asked to detail:
-
Bars, restaurants, lounges
-
Pool decks and outdoor areas
-
Casinos
-
Theatre/show venues
-
Cabin categories with TV/radio
-
Retail areas
-
Spa/fitness areas
This information determines the applicable tariff and total annual cost.
5. Streaming Services Do Not Replace PRO Licensing
A frequent misunderstanding is that:
A premium streaming subscription or a B2B music service automatically covers public-performance rights.
European PROs clearly state this is not the case.
-
Consumer services (Spotify, Apple Music, Amazon Music) are licensed only for private use.
-
Even professional music services (e.g., for retail or hospitality) typically license reproduction and access rights, not public-performance rights.
-
PRO licences still apply when music is played publicly on a ship.
Official guidance consistently states that public-performance rights must be obtained separately.
This applies in ports, in territorial waters, and in many cases also in international waters through reciprocal international agreements.
6. Compliance Checklist for Cruise Ship Operators
A practical summary for operators:
6.1. Identify Operating Waters and Port States
Determine which countries’ PROs are relevant based on embarkation ports, territorial waters, and flag states.
6.2. Identify the Responsible PROs
Examples:
-
Germany → GEMA
-
France → SACEM
-
Switzerland → SUISA
-
UK → PPL PRS / PRS for Music
-
Netherlands → BUMA/STEMRA + SENA
6.3. Catalogue Onboard Music Use
-
Background playlists
-
Retail and spa music
-
Theatre and lounge shows
-
DJ or dance events
-
TV/radio in cabins and public areas
6.4. Contact PROs or Their International Departments
They typically request the ship layout, surface areas, capacities, and the number of music zones.
6.5. Clarify Licensing Scope with Any Music Provider
Confirm which rights are included and which must be handled directly with the PRO(s).
6.6. Maintain Proper Documentation
Keep licences, invoices, and—where relevant—usage logs, event information, or setlists for live performances.
Conclusion
Cruise ships operate complex entertainment environments that require the same public-performance music licences as hotels, restaurants, bars, and entertainment venues on land.
European PROs — including GEMA, SACEM, SUISA, PRS for Music, and PPL PRS — require cruise operators to obtain appropriate licences when music is played onboard, whether recorded, streamed, broadcast, or performed live.
With proper licensing in place, cruise operators can ensure full copyright compliance across all routes and jurisdictions.