Aportaciones públicas sobre IA
CISAC’s Public Contributions on Copyright and AI
This page provides an overview of CISAC’s contributions to international public consultations and policy discussions on Copyright and Artificial Intelligence. CISAC advocates for strong copyright protection, transparency obligations for AI developers, fair licensing practices, and policies that safeguard creators in the digital environment.
US Consultation (2023)
The US Copyright Office launched a Notice of Inquiry (NOI) on issues relating to Copyright and Generative AI in 2023. CISAC provided two submissions which examined the application of the fair use exception to AI training, the implications of extending copyright protection to generative AI outputs, and the longstanding role of collective management organisations to facilitate collective licensing in the face of technological change. The US Copyright Office cited CISAC’s submission in its third Report on Generative AI Training [Pre-Publication].
US Copyright Office’s Study page: [Link]
Notice of Inquiry: [Link]
CISAC’s Initial Comment to the NOI (public) (Nov 2023): [Link]
CISAC’s Reply Comment to the NOI (public) (Dec 2023): [Link]
Canada Consultation (2023)
CISAC advocated against the use of copyrighted works for AI training without authorisation. CISAC urged the Canadian government to require developers to keep records of training datasets and to obtain licences or permissions for uses of protected works.
Australia Consultations (2024-2025)
CISAC contributed to three major consultations relating to AI regulation and copyright:
Select Committee on Adopting Artificial Intelligence (May 2024) CISAC warned of the significant risks posed by unregulated or insufficiently regulated AI technologies to creators and cultural diversity.
Consultation Page: [Link]
CISAC’s Submission (public): [Link]
PDF: CISAC Comments to the Australian Select Committee on Adopting Artificial Intelligence (AI)
Consultation on Mandatory Guardrails for High-Risk AI (October 2024) CISAC emphasised that high-risk AI systems must include safeguards that consider their impact on the creative sector, particularly regarding transparency and the use of copyrighted works.
Productivity Commission – Data & Digital Technology Interim Report (August 2025) With support from its Australian members, CISAC strongly opposed the introduction of a new Text and Data Mining (TDM) exception, reinforcing that Australia’s copyright law is already fit-for-purpose to encourage fair licensing of protected works. The government officially withdrew the proposal for the TDM exception in October 2025.
Hong Kong Consultation (2024)
CISAC advised the Hong Kong government against the adoption of a broad Text and Data Mining exception. CISAC recommended that, if implemented, such an exception must be limited to non-commercial uses, and must establish authorisation and adequate compensation mechanisms for creators.
PDF: CISAC Submission for Hong Kong's Public Consultation on Copyright and Artificial Intelligence
UK Consultation [2024]
CISAC encouraged the UK Government to adopt fair licensing practices and ensure safeguards against unauthorised uses of creative works throughout the AI value chain, and against the expansion of its TDM exception to commercial uses. CISAC also supported strong transparency obligations for developers.
Consultation Page: [Link]
PDF: CISAC Submission for the UK's Public Consultation on Copyright and Artificial Intelligence
India Consultation [2025]
CISAC submitted recommendations on AI policy ahead of India’s Stakeholder Consultation on Copyright and Artificial Intelligence on 20th June 2025 in Vanijya Bhawan, New Delhi, arguing that the involvement of multiple exclusive rights within the AI ecosystem is clear. CISAC also stated that core copyright principles — including originality and authorship — must not be altered or weakened in response to AI technologies.
EU Code of Practice [Ongoing]
CISAC, together with a coalition of authors, performers, and other rightsholders, opposed the third draft GPAI Code of Practice. The coalition argued that the Code fails to ensure compliance with EU copyright law and the AI Act, particularly regarding transparency, dataset disclosures, and lawful training practices. Currently, rightsholder organisations continue their concerns over the implementation of the EU AI Act to ensure that creators are provided with the transparency and tools they need to properly enforce their rights.
CISAC’s Participation in Joint Letter: [Link]
WIPO Conversations on IP and AI [2019-present]
WIPO official session pages:
2nd Session (2020) : WIPO Conversation on Intellectual Property (IP) and Artificial Intelligence (AI): Second Session
CISAC Written Statement: [PDF]
4th Session (2021): WIPO Conversation on Intellectual Property (IP) and Frontier Technologies
CISAC Written Statement: [PDF]
8th Session (2023): WIPO Conversation on Intellectual Property (IP) and Frontier Technologies
CISAC Written Statement: [PDF]
9th Session (2024): Ninth Session WIPO Conversation on Intellectual Property (IP) and Frontier Technologies
CISAC Written Statement: [PDF]
10th Session (2024): Tenth Session WIPO Conversation on Intellectual Property (IP) and Frontier Technologies
CISAC Written Statement: [PDF]
11th Session (2025): Eleventh Session of the WIPO Conversation
CISAC Written Statement: [PDF]
12th Session (2025): Twelfth Session of the WIPO Conversation: Intellectual Property and Synthetic Media
CISAC Written Statement: [PDF]