It continues to be a very busy time for copyright and collective licensing around the world. At CCC, we see it as an important part of our mission to monitor the copyright landscape and to keep our partners informed about the latest developments. This update summarizes a selection of important highlights from key jurisdictions.
In the United States, Congress and the Administration continue to debate AI-related policy issues, many of which relate to copyright. In December, the White House released an Executive Order “Ensuring a National Policy Framework for Artificial Intelligence” intended to address state laws regulating AI. The Executive Order: creates a task force to challenge what the White House believes to be burdensome state AI laws; asks for an evaluation of state AI laws; looks at whether states with AI-related laws can receive certain federal funding; and seeks the development of federal legislation. The Executive Order favorably references copyright, stating that any federal framework “should also ensure that children are protected, censorship is prevented, copyrights are respected, and communities are safeguarded.” Additionally, the Administration released in July its AI Action Plan that proposed a wide range of initiatives designed to promote the development and adoption of AI technologies. The plan did not propose any specific policy initiatives related to copyright. Following on the from the release of the plan, the Office of Science and Technology Policy published a notice seeking comments on possible regulatory reform relating to AI. Meanwhile, individual members of Congress have proposed various pieces of legislation that could impact copyright policy in relation to AI. It continues to be a very busy time for copyright in US courts, and we are monitoring scores of cases currently working their way through various levels of the US judicial system. CCC continues its advocacy efforts to advance copyright and licensing in the US and around the world.
In China, CCC participated in the Beijing International Book Fair in June and presented to publishers, academics, and government officials at conferences in Wuhan and Beijing promoting the importance of copyright and licensing, and in collaboration with IFRRO and the local RRO.
In Japan, the AI Act came into full force in September. The Act requires the government to produce a basic plan on AI and guidelines to ensure appropriate AI research, development, and use. First drafts of these documents were produced in November for a short period of public comment. The draft guidelines emphasize the importance of establishing “an ecosystem that returns benefits to data holders, such as IP owners, and create an environment that promotes creative activities.” It is expected that final versions of the plan and guidelines will be approved and published by the government by the end of 2025. In addition, the Japanese government is continuing meetings of its Committee for IP Rights in the age of AI. The work of the Committee is currently focused particularly on issues relating to transparency in AI systems.
Although the AI Act in the European Union came into force in 2024, many of its provisions take effect over time. Many apply from August 2026, but Chapter V regulating general-purpose AI models applied from August 2nd this year. Article 53 of this Chapter includes provisions requiring providers of general-purpose AI models to put in place a policy to adhere to copyright laws and to publish a detailed summary of the content used for training these models. There are many high-profile lawsuits at various stages of development in EU countries, including Denmark and Germany. In November, the Munich Regional Court delivered a landmark decision in the GEMA vs OpenAI case, ruling that both the memorisation of copyrighted texts during AI model training and their reproduction in chatbot outputs constitute acts of copyright infringement. Especially significant was the emphasis in the judgment that these uses are not covered under any copyright limitation or exception, including the TDM exception.
In the UK, International Federation of Reproduction Rights Organisations (IFRRO) joined a coalition of more than two hundred stakeholders from the EU’s and the UK’s Cultural and Creative Sectors (CCS) to develop a set of policy recommendation under the Forum on EU–UK Cultural & Media Relations. Approximately forty CCS representatives from the EU and the UK contributed to the development and drafting of the document. The Policy Recommendations stress that culture and creativity are vital to the political, societal and economic relationship between the EU and UK, particularly at a time of growth of the creative sectors, fast evolving technologies and new regulatory challenges.
CCC has always encouraged the expansion of voluntary collective licensing around the world by supporting new and nascent RROs. This has continued in 2025 with bilateral agreements being renewed with several RROs and a new agreement signed with VIETRRO in Vietnam. It is very satisfying to see these efforts come to fruitions, with RROs like the one in the UAE (ERRA) selling its first licenses.
CCC continues to work closely with IFRRO. We joined the 2025 regional committee meetings in Rabat (Africa committee), New Delhi (Asia Pacific committee), and Rio de Janeiro (Latin America and Caribbean committee), and made presentations there on various copyright and licensing issues, including Artificial Intelligence. In addition, CCC joined IFRRO leadership at a conference in Ho Chi Minh City to promote copyright awareness in Vietnam and support the local RRO, VIETRRO, and presented to a group of 40 representatives from African RROs on licensing and communication strategies. This event was part of a WIPO/IFRRO project to foster the development of African RROs. (The World Intellectual Property Organization (WIPO) is a specialized agency of the United Nations.)
It was a great pleasure to join the global community of RROs at the recent IFRRO World Congress held in Singapore. In addition to the usual full program, the 2025 Congress featured elections to its Board of Directors. I was elected as an RRO director for a three-year term. Tracey Armstrong, President and CEO of Copyright Clearance Center, stood down from the IFRRO board after many years of service, including a period as IFRRO’s President.