On July 13, 2026, the National Copyright Administration of China (NCAC) released a draft revision of the Regulations on the Implementation of the Copyright Law (the "Implementing Regulations") for public comment through August 12, expanding the current 38 articles to 49. 

China's Copyright Law underwent its third amendment in 2020 and took effect in June 2021, introducing substantial changes to the rights framework. As the Copyright Law's most important supporting regulation, the Implementing Regulations have now, years later, come up for revision, with the aim of turning those general provisions into concrete and operable rules. This effort aligns with China's continued push to strengthen IP protection and also responds to obligations under two international treaties — the Beijing Treaty on Audiovisual Performances and the Marrakesh Treaty.

The draft targets five key areas: 

(1) improving the definitions of protected works and clarifying ownership — most notably redefining "audiovisual works" to expressly cover web series, variety shows, and other new formats; 
(2) refining licensing and transaction rules, including the presumption-of-ownership rule extended to related rights, evidentiary weight for copyright registration certificates, and a longer payment period for statutory licenses, administered through collective management organizations; 
(3) strengthening enforcement, by listing five categories of infringement that "harm public interest" and improving the rules on technical protection measures and rights management information; 
(4) aligning with international treaty obligations, through a revised definition of "performer" and new accessibility rules for readers with print disabilities; 
(5) technical amendments to keep the regulation consistent with the Copyright Law.

Two changes are worth highlighting:

First, "audiovisual works" are no longer defined by production method — any sufficiently original content fixed as a sequence of moving images capable of being played back or transmitted now qualifies, bringing web series, variety shows, and similar formats squarely within scope. This gives streaming and short-video businesses a clearer framework for licensing and enforcement. 

Second, the presumption of ownership from a name on a work is now extended to related rights: anyone named on, or identified through a rights notice on, a performance, sound or video recording, layout design, or broadcast is presumed to be the rights holder unless rebutted by contrary evidence, shifting the evidentiary burden to the party disputing ownership. Registration certificates gain "prima facie" evidentiary status for the first time, helping to lower the cost of proving ownership, particularly for foreign rights holders. That said, registration is not conclusive — courts will still examine the creative process where ownership is genuinely contested, so companies should keep organized records alongside any registration.

Notably, the draft makes no mention of AI-related issues at all, at a time when such litigation is unusually active: by our count, dozens of AI-related disputes have already arisen in Chinese courts, most involving copyright, and the Supreme People's Court has begun drafting a judicial opinion on adjudicating AI-related disputes to work toward more consistent standards. The omission is unsurprising: with the law here still taking shape case by case and dedicated guidance already in the works, it would be premature to lock AI rules into an administrative regulation now — the draft appears to leave that space deliberately, rather than by oversight. The relevant rules continue to develop through the courts and through the guidance currently being prepared. Companies and creators would be well advised to monitor these developments and to address AI-related copyright compliance at an early stage.

Overall, the revision should lower the practical cost of establishing and transacting in copyright, make protection more workable in practice, and help the framework keep pace with the fast-moving and format-diverse digital content industry.

The draft remains open for comment, and its final provisions may still change. We will continue to monitor its progress, and welcome inquiries on copyright ownership and enforcement, contract structuring, or compliance strategy in this area.