DOI: 10.26650/ppil.2026.46.2.1918573 ISSN: 2667-4114

Copyright Protection for AI-Created Works: A Comparative Analysis of the UK, the EU, and Türkiye

İsmail Karaca
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This study analyses the legal and conceptual issues presented by generative AI within copyright law, focusing on developments in the European Union, the United Kingdom, and Türkiye. As AI systems progressively demonstrate the ability to produce original content—spanning literature, photos, music, and virtual environments—they challenge conventional notions of authorship, creativity, and ownership. The study examines how current legal frameworks address these changes, specifically with the requirement of originality and the function of human intellectual contribution.The comparative analysis indicates that both the EU and Türkiye uphold a strictly human-centric approach, rejecting copyright protection for works generated solely by AI without human creative input. The UK adopts a more flexible, although internally contradictory model, acknowledging human authorship as fundamental to originality while offering restricted protection for computer-generated works via regulatory measures. Uncertainty over the ownership and legal status of AI-generated products continues across all three nations.AI-generated works encounter legal protection challenges in intellectual property law, with strategies that have their pros and cons. Treating AI as an “employee” fits legal frameworks but may misrepresent AI's abilities. Granting AI legal personhood acknowledges machine autonomy but poses ethical issues. Re-evaluating originality requirements could resolve doctrinal problems but might undermine human-centric copyright. A hybrid model that modifies originality standards or creates sui generis protections while ensuring human authorship could offer a balanced solution.The author proposes recognition of AI authorship, arguing that legal reforms are needed to prepare for its inevitability. A sui generis framework, distinct from traditional copyright, should be created to protect AI-generated works, clarifying eligibility for protection, establishing ownership rights based on control over the AI, and limiting the scope and duration of rights to between 5 and 15 years to prevent monopolisation. Transparency measures, such as identifying AI-generated content, may also be required to foster access for educational purposes while balancing investment incentives in AI systems.

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