EIFL and its partner, The Association of Electronic Libraries in Kosova (AELK), submitted comments on the Draft Law on Copyrights and Related Rights (2022). The comments were submitted for a public consultation organized by the Ministry of Culture, Youth and Sports of the Republic of Kosovo.

The comments by AELK and EIFL concern exceptions for blind and visually impaired persons, libraries and the three-step test. There are six recommendations. Four recommendations relate to the making of accessible format copies: authorized entities, such as libraries, should be explicitly allowed to make and distribute accessible format copies, as well as to import and export. A person acting on behalf of a blind or visually impaired person, such as a family member, should also be allowed to make accessible copies, and beneficiaries of the exception should have legal recourse if technological protection measures prevent the exercise of the exception. The fifth recommendation calls for the exception for replacement copies by libraries to include the making of digital copies, while the sixth recommendation calls for the deletion of the article on the three-step test.