Machine-Actionable Copyright Data: Interoperable Infrastructure Supports All Stakeholders

Artificial intelligence (AI) is reshaping the copyright landscape, but the debate is no longer limited to legislation and emerging case law. Generative AI (GenAI) is exposing an infrastructure gap in copyright: law can establish rights and obligations, but those rights cannot be implemented effectively at digital scale without interoperable, trustworthy and machine-actionable rights data.

Recent work by the European Commission and European Union Intellectual Property Office (EUIPO) already discussed in previous blogposts (see here and here) indicates that we are moving toward a more coordinated approach to copyright data governance and interoperability.

The mapping study on EU databases and metadata standards commissioned by the EUIPO confirmed the challenges associated with rights management information in the cultural and creative sectors. It identified several potential applications for a future CopyrightView service, including information discovery, metadata matching, rights clearance, licensing support, and deduplication of records. It also emphasized the importance of awareness-raising and education as part of the infrastructure agenda.

The feasibility study on an EU-level opt-out registry by the European Commission (DG CNCT) examined whether an EU-level registry for the “opt-out” based on Article 4 of the DSM Directive could improve the visibility and discoverability of such rights reservations.

The study concluded that a European registry could provide a valuable complementary tool alongside existing solutions. Rather than replacing sector-specific mechanisms, it would increase transparency and improve the effectiveness of TDM opt-outs across the EU.

On 15 September 2026, EUIPO presented EU copyright infrastructure as a strategic goal at its Observatory Plenary Meeting in Alicante. It will convene a CopyrightView Expert Group based on applications submitted by to the EUIPO Observatory.

The Commission announced a pilot project on the opt-out registry as a next phase.

An Open Rights Data Framework - ORDF

The Member State-led and funded Copyright Infrastructure Task Force (CITF) covering 125 experts from 32 countries provides crucial support in the promotion of interoperability, trustworthiness and machine-actionability of copyright data. Actions that are necessary to achieve transparency of AI training on content level.

A key contribution is a recent report "Copyright Infrastructure Task Force - Status Quo and Way Forward" which was handed over to the European Union, EUIPO and WIPO on 8 July this year to contribute to the various ongoing workstreams. The report was well received and valued useful.

The report promotes and lays a foundation for the development of an Open Rights Data Framework (ORDF) across cultural and creative sectors, distribution channels, and jurisdictions to make identifiers and metadata schemes clear and concise and to support automated processes in the digital and AI era. The ORDF encourages the use of open standard identifiers, recommended metadata schemes and new technologies such as watermarking and fingerprinting to build trust and to support rights management throughout the entire lifecycle of media assets.

The CITF report recommends strengthening the semantic layer of copyright infrastructure, as a distinct middle layer of the overall structure that has the legislation as a basis and is implemented through the technology or business layer on top.

The CITF First Project report published in October 2025, led by the National Library of Finland, lays a foundation for the ORDF by identifying 76 requirements covering the lifecycle of a work, serving respective needs of the stakeholders of the copyright system for rights management information, transparency and traceability of works in 2030. These criteria were reviewed through stakeholder feedback sessions, followed by dedicated online discussions on ongoing work within standards-development organizations and associations representing needs of rightsholders. All presentations are available at the CITF webpage.

Moving forward, the ORDF should be developed pragmatically through testing and validation using real-world use cases and pilot projects conducted within the cultural and creative sectors.

The ORDF could facilitate automated licensing, rights verification, human attribution, remuneration and other digital services while allowing sectors to maintain their own specialized solutions reflecting their specific needs. The framework is intended to support not replace existing infrastructures.

Future copyright systems must be capable of supporting digital and AI-driven uses of creative content in 2030 and beyond.  The first wave of digital copyright policy development, more than 30 years ago, recognized the importance of rights management information and the need to protect it from removal and alteration. Something that has not been addressed and still takes place frequently and undermines the value of metadata.

The Gen AI wave provides a momentum for building interoperable infrastructure for rights information where metadata on copyright is collected and maintained from creation to production, management and use, thereby enabling original creators to be remunerated and participate in the AI value chain from the outset. Current mechanisms start late - with production.

Developing sustainable governance and maintenance models at European and international levels requires a clear policy goal set by the EU and coherent funding of large-scale pilot projects from institutional funding programs. It also requires a strategic approach at the national level.

Copyright infrastructure development started nationally immediately after Finland had raised the topic on the EU level in 2019. These efforts, including funding initiatives on metadata quality and dedicated subgroup discussions on culture and workflow have produced internationally significant comparative data on the process and benefits of modernizing copyright infrastructure involving all cultural and creative sectors. One example is the adoption of ISNI identifiers issued by the National Library to all members of Finnish collective management organizations.

Governance and International Cooperation

The success of these initiatives will ultimately not depend on technology but on governance, and on a broader cultural shift toward recognizing that effective legislation must be underpinned by appropriate data infrastructure. The responsibility should lie with the institutions and organizations mandated to promote effective protection of Intellectual property.

The CITF report highlights the need for sustainable and coordinated funding, institutional support and long-term maintenance. Questions remain regarding where responsibility for the open rights data framework should ultimately reside. Some stakeholders favor an EU-based governance model at the EUIPO Copyright Knowledge Center, while others highlight the importance of alignment with international efforts, such as the WIPO AI Infrastructure Interchange AIII launched earlier this year.

Europe is entering a new phase of copyright policy in which infrastructure is required to complement legislation. Following this, neither the CopyrightView service nor a TDM opt-out registry should be introduced without promoting a common framework for interoperable copyright data, such as the Open Rights Data Framework to generally serve all creative sectors and to ensure a level playing field in accessing new technologies and services.

Building EU copyright infrastructure is like renovating an old log house. Rather than moving too quickly to implement quick solutions and services, policymakers should commit to a long-term approach, establish a solid foundation, and preserve existing structures while demonstrating a shift toward practical mechanisms that can support improved copyright management in the AI era.

The central challenge now is governance. Decisions taken in the coming years regarding funding, institutional responsibility, and international cooperation will be critical to determining its success. If successful, the emerging framework could provide the foundations for a copyright ecosystem that is interoperable, trustworthy, and capable of supporting both creative industries and AI innovation in an increasingly digital world. 

Image - CiTF logo: The letters C stand for Copyright, Content, and Creativity in relation to the infrastructure. The gap in the chain shows the work still needed to improve the exchange of copyright data. The letter i stands for infrastructure and human affirmation. The Ci logo emphasizes the central role of humans in the fast-evolving AI age.