As countries adopt divergent approaches to regulating AI’s dependence on copyrighted materials, India considers a hybrid model to balance innovation, creator rights, and legal clarity amid global uncertainties.
As governments and courts grapple with how artificial intelligence should be allowed to learn from copyrighted material, the debate is increasingly shaping the economics of both innovation and creative labour. The core question is no longer whether AI models depend on protected works, but how that dependence should be regulated in a way that preserves incentives for creators without stifling technological development.
In the United States, the legal answer still turns largely on fair use, a flexible doctrine that leaves judges to weigh each dispute on its own facts. That approach gives AI developers room to argue that model training is transformative, but it also creates uneven outcomes, especially when courts differ over the significance of lawful access and market harm. The US Copyright Office has signalled sympathy for research and innovation uses, while also favouring voluntary licensing arrangements rather than a broader statutory overhaul.
The European Union has taken a more codified route. Its copyright rules contain explicit text-and-data-mining exceptions, including a narrower provision for scientific research and a broader one for commercial use where material is lawfully accessed and rights holders have not opted out in machine-readable form. The EU’s artificial intelligence regime adds another layer, requiring providers of general-purpose models to adopt copyright compliance policies, respect opt-outs and disclose training data summaries, reflecting a more interventionist style of governance.
China’s framework is more tightly controlled and state-led. Its rules require lawful sourcing of training data and do not offer a dedicated text-and-data-mining exemption for AI training, but judicial guidance has left room for a more flexible “reasonable use” interpretation in some cases. That combination creates a system that is cautious, compliance-heavy and closely aligned with broader state objectives around technological development.
India, by contrast, is still working through the legal uncertainty. Its Copyright Act does not currently contain a specific provision for AI model training, and the scope of fair dealing remains unclear for large-scale commercial uses. The Delhi High Court’s pending decision in ANI v OpenAI has become a key test of whether training on copyrighted news content can be justified under existing law. Alongside the litigation, policymakers are considering a collective licensing model, described in a government working paper as “One Nation, One License, One Payment”, under which access would be simplified and royalties would be triggered at the point of commercialisation.
Taken together, the international picture shows that there is no single settled model for AI and copyright. The most workable path for India may be a hybrid one: clearer statutory guidance on fair dealing, a licensing system that compensates rights holders at scale, and safeguards for smaller developers so that compliance does not become a barrier to entry. The underlying challenge is to build a regime that is predictable enough for investment, fair enough for creators and flexible enough to adapt as AI systems continue to evolve.
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Source: Noah Wire Services
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The draft above was created using the information available at the time the story first
emerged. We’ve since applied our fact-checking process to the final narrative, based on the criteria listed
below. The results are intended to help you assess the credibility of the piece and highlight any areas that may
warrant further investigation.
Freshness check
Score:
7
Notes:
The article was published on April 20, 2026. Similar discussions on AI training and copyright have been reported in recent months, notably in December 2025, when India proposed a mandatory royalty system for AI companies training models on copyrighted content. ([techcrunch.com](https://techcrunch.com/2025/12/09/india-proposes-charging-openai-google-for-training-ai-on-copyrighted-content/?utm_source=openai)) However, the specific comparative legal frameworks presented in this article appear to be original. ([insightsonindia.com](https://www.insightsonindia.com/2025/12/11/generative-ai-copyright-one-nation-one-license/?utm_source=openai))
Quotes check
Score:
6
Notes:
The article includes direct quotes from various sources. However, these quotes cannot be independently verified through the provided search results. This raises concerns about the authenticity and accuracy of the quoted material.
Source reliability
Score:
8
Notes:
The article is published on the Observer Research Foundation’s website, a reputable think tank in India. However, the lack of independent verification for some quotes and the absence of citations for certain claims slightly diminish the overall reliability.
Plausibility check
Score:
7
Notes:
The article presents a coherent analysis of AI training and copyright laws across different jurisdictions. While the general claims align with known legal frameworks, the specific details and interpretations presented cannot be fully verified, raising some doubts about their accuracy.
Overall assessment
Verdict (FAIL, OPEN, PASS): CONDITIONAL
Confidence (LOW, MEDIUM, HIGH): MEDIUM
Summary:
The article provides a detailed analysis of AI training and copyright laws across different jurisdictions. However, the inability to independently verify some quotes and the absence of citations for certain claims raise concerns about the accuracy and reliability of the information presented. It is recommended to cross-reference the claims with other reputable sources before publication.
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