ALPSP welcomes the publication of the UK Government’s Report and Impact Assessment on Copyright and Artificial Intelligence.  

We recognise the considerable work undertaken by DSIT, DCMS and the IPO to deliver a detailed and balanced analysis of how best to support both the UK’s world‑leading creative industries and its rapidly expanding AI sector.  We would like to highlight several key issues addressed in the report.

Taking the Time to Get This Right

We support fully the Government’s commitment to ensuring that any reforms are proportionate, evidence‑based and aligned with the UK’s long‑term strategic objectives.  The stated position—“We will not introduce reforms to copyright law until we are confident that they will meet our objectives for the economy and UK citizens”—is both prudent and necessary.  Reform must safeguard the UK’s creative strength while enabling AI to contribute meaningfully to innovation, economic growth, and public benefit.

Recognition of Value in the Licensing Market

We welcome the Government’s recognition of the significant value that creative content brings throughout the AI development lifecycle.  As the report notes, “The evolving licensing market demonstrates that creative materials can add value in the AI supply chain.  The government believes right holders should be fairly remunerated for this value.”  We agree that a market‑led approach can continue to progress, provided the Government maintains appropriate oversight to ensure that creators and rights holders are not disadvantaged by asymmetries of power, scale or information.

The commitment to develop best practices in input transparency and technical standards and to keep licensing outcomes under review, is a constructive step.  These measures can strengthen future licensing frameworks without prematurely constraining innovation.

Transparency and Labelling

We support the Government’s intention to work with industry to develop best practice on input transparency, enabling rights holders to understand when and how their works are used in AI development.

We also recognise the importance of exploring consistent and effective approaches to labelling AI‑generated content.  Clear labelling will help build public trust, support provenance tracking and reduce the risk of confusion or misuse as generative technologies become increasingly sophisticated.

Enforcement and Accessible Redress

ALPSP welcomes the Government’s emphasis on strengthening enforcement mechanisms and its commitment to work with industry, law enforcement and the judiciary to ensure clear and accessible routes to redress for those affected by AI‑related infringement.  In an environment where scale, speed, and opacity pose significant challenges, coordinated action is essential.

AI Impersonation and Personality Rights

We note the Government’s assessment of risks arising from realistic AI‑enabled impersonation affecting both creators and the public.  The proposal to explore the potential introduction of a new personality right represents a thoughtful and forward‑looking initiative.  We look forward to engaging with Government on how such a right might interact with existing copyright, data‑protection, and commercial frameworks.

A Spirit of Cooperation

Finally, we welcome the report’s emphasis on collaboration across the creative industries, AI developers, legal authorities, and technical experts. Meeting challenges of this scale requires coordinated, evidence‑driven solutions.

ALPSP remains committed to working closely with the Government as it continues its engagement and evidence gathering.  As AI technologies evolve, our members will continue to support responsible innovation while ensuring that creators and rights holders retain the ability to control, license, and benefit fairly from their work.

We stand ready to contribute to the next phase of this important work.