The EUIPO’s Metadata Mapping Study: Towards a European Copyright Infrastructure

On 28 May 2026, the European Union Intellectual Property Office (EUIPO) published its study on “Mapping of EU Databases and Metadata Standards Providing Information on Copyright-Protected Works” (available here). This report represents a significant step in the EU’s ongoing effort to modernise copyright infrastructure and adapt it to an increasingly digital, data‑driven ecosystem.

The study’s central premise is straightforward but far-reaching: reliable, accessible metadata on copyright‑protected works is a necessary condition for effective licensing, remuneration, and enforcement particularly in the context of cross-border uses and emerging technologies such as generative artificial intelligence (GenAI).

Metadata as the “Passport” of Copyright Works

The report emphasises the functional role of metadata in the copyright ecosystem. Metadata is the information about authorship, ownership, and usage conditions. It acts as a “passport” for creative works, enabling identification, licensing, and remuneration.

However, the study finds that the current system is fragmented across the EU. Data relating to works and rightsholders is dispersed across numerous public and private databases, often relying on incompatible identifiers and standards.

This fragmentation has several concrete consequences:

• duplication of records across databases;

• inconsistencies in metadata;

• increased transaction costs for licensing; and

• legal uncertainty regarding ownership and rights status.

While these issues are not new, the study offers a systematic mapping of their scale and structural causes across multiple cultural and creative sectors.

Fragmentation and Interoperability: A Structural Problem

A key insight of the study is that fragmentation is not merely technical but structural. Different sectors, such as music, film, publishing and software, have developed sector-specific data practices reflecting distinct business models and historical trajectories. Even where international identifiers and metadata standards exist (e.g. ISBN, ISRC, ISWC, ISNI), their uptake remains uneven across industries and jurisdictions. As a result, interoperability, which is the ability of systems to exchange and meaningfully use data, is limited. In practice, data exchange often relies on ad hoc mechanisms, which undermines scalability and reliability. The report thus confirms a long-standing diagnosis, that the EU copyright landscape contains multiple databases but no system.

The Emergence of CopyrightView

Against this background, the EUIPO proposes the development of “CopyrightView”, an EU-level initiative intended to improve access to reliable copyright information by interconnecting existing databases. Importantly, the study does not advocate the creation of a centralised database. Instead, it suggests a model based on interoperability and coordination, in which existing data providers retain control over their data.

Potential use cases identified in the report include:

• Applications relating to the management, licensing, enforcement, and remuneration of copyright and related rights;

• The provision of information, as well as traceability and transparency in rights management; and

• Both the proactive implementation and reactive enforcement of the EU acquis for example by facilitating compliance with transparency, reporting, and rights reservation obligations, and by supporting the detection of unauthorised uses or discrepancies in rights information through enhanced data access and interoperability, in close cooperation with stakeholders.

Stakeholders appear broadly supportive of such an initiative, provided that it respects existing infrastructures and avoids centralised duplication.

AI, TDM and the Renewed Importance of Metadata

One of the most timely aspects of the study is its implicit connection to GenAI and data governance. EU copyright legislation, including the Directive (EU) 2019/790 on ‘Copyright in the Digital Single Market’ relies on the availability of accurate metadata, particularly in relation to TDM opt-outs. Yet, as the study shows, metadata is often incomplete, inconsistent, or inaccessible in practice.

In the context of AI, this creates at least three challenges:

1. Identification of protected works in training datasets;

2. Verification of rights status and permitted uses; and

3. Operationalisation of opt-out mechanisms.

The study suggests that improved metadata infrastructures could play a crucial role in addressing these challenges, effectively linking copyright law with emerging AI governance frameworks.

Legal and Policy Constraints

The report also highlights non-technical constraints that shape the metadata landscape. These include:

• data protection requirements;

• legal limitations on data sharing; and

• sector-specific governance arrangements.

These constraints complicate any attempt to build interoperable systems, as they require balancing transparency with compliance and commercial sensitivities. Moreover, the study underscores the importance of incentives, as interoperability cannot be achieved solely through technical standardisation but requires stakeholders to actively record and share high-quality metadata.

Assessment: Incrementalism or Transformation?

The EUIPO study is best understood as a foundational mapping exercise rather than a fully-fledged policy proposal. Its primary contribution lies in documenting the current state of play and identifying pathways for future development.

Two aspects deserve particular attention:

• Incremental approach. The focus on interoperability over centralisation reflects a cautious, pragmatic strategy that seeks to build on existing infrastructures rather than replace them.

• Infrastructure thinking. The study signals a broader shift in EU copyright policy towards building copyright infrastructure as a complement to legal harmonisation.

Whether this approach will deliver meaningful improvements depends on several open questions, including governance models, funding, and stakeholder incentives.

Conclusion

As the first concrete deliverable of the CopyrightView initiative, this study maps the complex and fragmented European copyright data landscape. Currently, information remains scattered across public and private databases governed by disjointed mandates, legacy systems, and varying legal constraints. This lack of interoperability triggers major inefficiencies, including high transaction costs, data duplication, and reduced transparency for creators and rights holders. To build a sustainable, interconnected infrastructure, future efforts must focus on establishing common technical standards and creating clear incentives for stakeholders to adopt consistent metadata practices.

Importantly, CopyrightView is positioned not as a new centralised or replacement database, but as a federated transparency layer facilitating structured access to existing data networks. Moving forward, these insights will guide the CopyrightView Expert Group, shape upcoming feasibility studies, and support the EUIPO Copyright Knowledge Centre. Ultimately, this study establishes a baseline for future policy and technical choices aligned with broader European data governance and interoperability goals.

Photo by Markus Winkler on Unsplash