This is a survey result summary report published by the Agency for Cultural Affairs in March 2025, investigating the impact of AI technology and digital technology advances on copyright systems and examining trends in various countries.
Survey Background and Purpose
With rapid advances in artificial intelligence (AI) and digital technologies, new challenges unforeseen by copyright systems have emerged globally in various countries. Issues including learning and use of copyrighted works by generative AI technology, content distribution on digital platforms, and new copyright transaction formats utilizing NFT and blockchain technologies increasingly fall outside the scope of conventional copyright law frameworks. This survey was conducted to systematically understand legal system development status, policy responses, and judicial judgment trends in various countries regarding these challenges, serving as basic material for examining future directions of Japan's copyright system.
Each Country's AI and Copyright Policies
Various approaches are taken regarding AI technology and copyright relationships in surveyed countries. The US shows relatively flexible responses to AI learning-purpose copyright work use through expansive interpretation of "fair use" concepts, while the European Union (EU) emphasizes stricter rights protection and transparency assurance through implementation of the "Digital Single Market Copyright Directive."
The UK adopts a unique balanced approach, considering introduction of AI learning exception provisions under specific conditions to balance AI research and development promotion with rights holder protection. Asian countries and regions including South Korea and Taiwan are also actively discussing copyright system flexibility from AI technology development and cultural industry promotion perspectives.
Digital Platform Regulation
All countries are advancing regulatory strengthening for digital platform operators, with legal mandates including automatic detection and removal system introduction obligations for copyright-infringing content, appropriate compensation distribution mechanism construction for rights holders, and transparency report publication obligations. Particularly, the EU's "Digital Services Act" and "Digital Markets Act" draw international attention as pioneers of comprehensive regulation for large-scale platforms, significantly influencing other countries' policy formation.
Legal Responses to New Technologies
Legal frameworks are advancing in various countries regarding relationships between emerging digital technologies and copyright, including copyright work use in NFT (Non-Fungible Token) and metaverse spaces, and rights management systems utilizing blockchain technology. Important discussion points include how these technologies apply to existing copyright concepts (reproduction rights, public transmission rights, adaptation rights) and the necessity of international unified standards.
Need for International Coordination
Survey results indicate that individual country responses have limitations in copyright system development responding to digital technology advances, with international coordination and unified standard establishment being indispensable. The importance of multilateral consultations at WIPO (World Intellectual Property Organization), bilateral and multilateral treaty amendments, and multi-stakeholder dialogue including private companies is emphasized.
The article concludes that copyright systems in the AI era require flexible yet effective system design balancing technological innovation and rights protection under international coordination.