Copyright, including in software, arises without registration in the UK and France, and registration is only optional in the UAE and Saudi Arabia, so ownership and evidence often matter more than filings. Terms run for the author's life plus 70 years in the UK, Germany and Singapore, and life plus 50 years for economic rights in the UAE. Registration is optional in the UAE and Saudi Arabia, but in the United States registration is needed before suing over a US work and affects the remedies available.
Protection without registration, with exceptions
In the UK there is no application, fee or official register, and the copyright symbol is optional. France protects an original work from its creation without formality. The UAE and Saudi Arabia keep optional registers that serve as evidence of data and ownership. India has been a member of the Berne Convention since 1928 and protects works under the Copyright Act 1957.
The United States is different in practice: no infringement action can be brought for a US work until it is registered or registration is refused, and statutory damages and attorney's fees are generally unavailable for infringement that began before registration unless a published work is registered within three months of publication. Businesses that rely on software or content in the US should register key works early.12345678
Duration and data mining
Copyright in literary and artistic works lasts 70 years after the author's death in the UK, Germany and Singapore, while UAE economic rights last for life plus 50 years. Different terms apply to films, sound recordings and broadcasts.
Singapore's Copyright Act 2021 permits copying for computational data analysis, including machine-learning training, where the user has lawful access, and this exception cannot be overridden by contract. Other markets take different approaches, which matters for AI training and data projects.910111213
| Market | Term for authors' works | Registration | Source |
|---|---|---|---|
| United Kingdom | Life plus 70 years | None; automatic | GOV.UK |
| Germany | Life plus 70 years | Not researched | UrhG § 64 |
| Singapore | Life plus 70 years | Not researched | Copyright Act 2021 |
| UAE (federal) | Life plus 50 years (economic rights) | Optional; not a condition of protection | Federal Decree-Law 38 of 2021 |
| Saudi Arabia | Not researched | Optional with SAIP | SAIP |
| United States (federal) | Not researched | Needed before suing for US works; affects remedies | 17 U.S.C. 411, 412 |
| France | Not researched | None; protected from creation | service-public.fr |
Decisions to make
- Will the business need to enforce in the United States?78US registration is a precondition to suing over US works and early registration preserves statutory damages.
- Who created the code and content, and under what terms?12Automatic protection vests in the author unless law or contract moves it; see the ownership module.
- Is the business training models on third-party data?13Text and data mining exceptions differ; Singapore's cannot be overridden by contract.
Documents usually needed
- Dated records of creation (repositories, drafts)
- Contributor and contractor agreements
- US copyright registrations for key works
- Open-source licence inventory for software
- Optional registration certificates in the UAE or Saudi Arabia where useful as evidence
Common mistakes
- Assuming registration is needed everywhere, or nowhere
- Waiting until infringement to register in the US
- Not tracking open-source components in software
- Treating contractor-written code as owned without a written assignment
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- Copyright terms in India, Saudi Arabia, France and the US were not confirmed (the Indian copyright office page on terms could not yet be checked).
- Text and data mining rules outside Singapore were not researched.
- US Copyright Office fees were not researched.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Copyright in the UK is automatic: there is no application, fee or official register of copyright works, and marking a work with the © symbol is optional. Covers original literary, dramatic, musical and artistic works, software, databases, sound recordings, films, broadcasts and published edition layouts.
Reused from gb-ip-g20.
An original work is protected by copyright in France from its creation, even before it is completed, without any formality. Evidence of the creation date is a practical matter, not a condition of protection.
Reused from fr-ip-008.
Under Federal Decree-Law No. 38 of 2021 on Copyright, not registering a work does not affect its protection; the Ministry's registers serve as a reference for the work's data and ownership. Federal.
Reused from ae-ip-011.
Copyright is governed by the Copyright Law issued in 2003 and amended in 2018, and registration of copyright works with SAIP is optional under SAIP's Regulations for the Optional Registration of Copyright Works.
Law title and amendment year confirmed on the WIPO Lex country profile. Reused from sa-ip-008.
India is a member of the Berne Convention for the Protection of Literary and Artistic Works, with effect from 1928. WIPO Lex lists entry into force for India on 1 April 1928.
WIPO Lex shows an instrument date of 23 April 1928 later than the entry-into-force date; shown as published. Reused from in-ip-004.
Copyright is governed by the Copyright Act 1957 (Act No. 14 of 1957), in force since 21 January 1958 and amended up to Act No. 18 of 2023. Central law; the Copyright Rules 2013 apply to procedure.
Reused from in-ip-007.
No civil action for infringement of copyright in a United States work may be brought until the copyright has been preregistered or registered, or registration has been refused. Federal. Applies to the United States works; foreign works from treaty countries are not subject to this precondition.
Statutory text read on the Cornell Legal Information Institute reproduction of the United States Code; the official text is published at uscode.house.gov. Reused from us-ip-008.
Statutory damages and attorney's fees for copyright infringement are generally unavailable for infringement that began before registration, unless a published work is registered within three months of first publication. Federal. Applies to domestic and foreign works alike.
Statutory text read on the Cornell Legal Information Institute reproduction of the United States Code; the official text is published at uscode.house.gov. The application to foreign works is our reading of the section, which contains no exception for them. Reused from us-ip-009.
UK copyright in literary, dramatic, musical and artistic works lasts 70 years after the author's death; sound recordings 70 years from first publication; films 70 years after the death of the last of the director, screenplay author and composer; broadcasts 50 years; published edition layouts 25 years. Duration can depend on when the work was created.
Reused from gb-ip-g21.
Copyright in Germany expires seventy years after the death of the author. General rule; special terms apply to some related rights (not reviewed).
Reused from de-ip-007.
The Copyright Act 2021 came into force on 21 November 2021, and authorial works with known authors are protected for 70 years after the author's death. Films and anonymous or pseudonymous works are protected for 70 years from making, making available or first publication, as applicable.
Reused from sg-ip-010.
An author's economic rights are protected for the author's lifetime and 50 years after death, counted from the start of the calendar year following death; the Copyright Decree-Law has applied since 2 January 2022. Federal; other terms apply to other categories of work.
Reused from ae-ip-012.
The Copyright Act 2021 permits copying of works for computational data analysis, including text and data mining and machine-learning training, where the user has lawful access, and this exception cannot be overridden by contract. Copies may not be shared except to verify results or for collaborative research, and may not be used for other purposes.
Reused from sg-ip-012.
Questions on this topic
13 statements on copyright and software
