LEGAL REGULATION OF AI-GENERATED WORKS: A COMPARATIVE ANALYSIS

Abstract

The purpose of the article is to provide a comprehensive comparative legal analysis of the regulation of AI-generated works across selected jurisdictions, including the United States, the United Kingdom, Japan, Ukraine, the European Union, Canada, China, and Australia, in order to identify common trends, key divergences, and potential directions for the harmonization of intellectual property law in the context of artificial intelligence. Research methods: combination of general scientific and special legal methods. In particular, the method of comparative legal analysis was employed to examine differences in national approaches to the regulation of AI-generated works across various jurisdictions. The method of documentary analysis was applied to the examination of legislative acts, judicial decisions, and policy documents governing intellectual property and artificial intelligence. In addition, the methods of synthesis and generalisation enabled the formulation of conclusions regarding current trends and future prospects in the legal regulation of AI-generated works. Results: the main legal approaches to determining the legal status of works created by artificial intelligence differ significantly depending on the jurisdiction; however, in most legal systems, the principle of human authorship remains a mandatory prerequisite for granting legal protection. At the same time, a considerable degree of legal uncertainty has been identified regarding issues of authorship, ownership rights, and liability for the use of such outputs. Discussion: the legal regulation of artificial intelligence and AI-generated works is currently undergoing active development in many countries. At the same time, the absence of unified international standards creates significant divergences in national approaches and may complicate the cross-border use of AI-generated content.