The Pulse
Philippines Seeks Comments on Draft AI Copyright Guidelines by Oct. 30
The Intellectual Property Office of the Philippines is accepting public comments on draft guidelines for registering AI-related works through Oct. 30, 2026. The proposal would tie protection to original human expression and leave questions
AI.info Team · Written with AI ·
The Intellectual Property Office of the Philippines is accepting comments through Oct. 30 on draft guidelines for registering works made with artificial intelligence. The proposal, titled Guidelines on the Registrability of AI Systems and AI-Related Works, puts original human expression at the center of whether an AI-related work can qualify for copyright registration.
The consultation page invites stakeholders and other interested parties to send feedback by email to copyright@ipophl.gov.ph. IPOPHL announced the draft on Sept. 17, after the agency’s Bureau of Copyright and Related Rights presented it at an initial public consultation. The guidelines remain a proposal, not a final rule.
Four kinds of AI-related work
The draft distinguishes among AI-assisted, AI-enhanced, hybrid and AI-generated works. AI-assisted work uses a system during the creative process, while the person contributes original expression; the agency’s example is a writer who selects AI suggestions, rewrites passages and arranges the final text. An AI-enhanced work begins with a human-created work, such as a photograph, that is later modified with AI.
Hybrid work combines human-authored and AI-generated material. IPOPHL’s example is a songwriter who writes lyrics and uses AI to generate a melody: registration could cover the work if the human contribution meets copyright requirements, but would not extend protection to AI-generated elements that do not qualify. By contrast, an output produced from a general prompt without further creative input would not receive protection to the extent it lacks original human expression.
Examiners would weigh the whole application
The draft defines human creative contribution as original expression by a natural person that meets the minimum creativity required for copyright protection. IPOPHL says originality depends on independent creation and intellectual creativity and judgment, rather than a fixed threshold. The proposal does not set a single test for deciding how much human contribution is enough.
Instead, the agency may consider the nature and extent of the person’s contribution, the AI system’s role, how generated elements were selected or modified, and the information the applicant submits. IPOPHL may ask for more information when it needs it to assess an application. The draft says those factors should be considered together in the circumstances of each case.
Registration would not resolve training-data disputes
The proposal also addresses copyright registration for AI systems. Registration would cover only copyrightable expression in the submitted computer program, not the system’s training data, materials used to train it, AI outputs or other material outside that program. IPOPHL says registration would not decide whether the training data or practices were lawful or constituted fair use.
That boundary is central to the proposal: it concerns how IPOPHL would treat registration applications, not whether a developer had permission to use particular works to train a system. Director General Teodoro C. Pascua said the guidelines “do not regulate AI generally or make a definitive determination on the copyrightability of AI-related works, but aim to provide greater clarity on their treatment for registration with IPOPHL.”
IPOPHL says the draft is still being refined
Comments received during the consultation are expected to inform revisions, IPOPHL said. Bureau of Copyright and Related Rights Director Emerson G. Cuyo described the aim as giving applicants practical guidance while leaving room to adjust the approach: “We want a framework that provides clarity without getting ahead of the technology. We want to give stakeholders a practical basis for navigating AI-assisted works while allowing us to refine the approach as dialogues deepen and experience accumulates.”
Interested parties have until Oct. 30 to email their comments to IPOPHL. The agency has not presented the draft as a final determination on copyrightability; it is a proposed framework for assessing what, within an AI-related work, can be attributed to human creative contribution for registration.