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19 August 2026

South Korea Opens The Door To Copyright Registration Of AI-Assisted Works

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Sheppard, Mullin, Richter & Hampton LLP

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South Korea’s largest music copyright collective, the Korea Music Copyright Association (“KOMCA”), has reversed its prior ban on registering AI-assisted musical works.
South Korea Intellectual Property
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South Korea’s largest music copyright collective, the Korea Music Copyright Association (“KOMCA”), has reversed its prior ban on registering AI-assisted musical works. The change expands what can be registered, but it comes with stricter disclosure requirements and more explicit enforcement tools.

KOMCA announced the revised registration standards in a notice dated August 4, 2026, and the amended rules took effect immediately.

KOMCA Moves From a “Zero Percent” Rule to Conditional Acceptance of AI

KOMCA’s new approach replaces its earlier “zero percent” policy, which took effect March 24, 2025. Under that prior rule, creators were required to confirm that a work was made solely through human creative contributions, with no AI involvement.

Under the revised system, KOMCA will register AI-assisted works when a human creator made a substantial and leading creative contribution, which, according to KOMCA’s copyright registration form, updated as of August 3, 2026, means that human creative involvement accounts for more than half of the creative process. However, KOMCA draws a bright line against prompt-only generation. In practice, the applicant must confirm that the work did not result solely from prompts.

Disclosure is Essential to Registration

Applicants must now identify and affirm which parts of a work involved AI, the AI tools used, how each tool was used, and the human creative contribution for each relevant part, including lyrics, composition, and arrangement. This is not framed as a general “AI was used” statement. Rather, disclosure requires a detailed account of where AI was involved and what the human creator contributed.

Additionally, registration of an AI-assisted work requires the registrant’s individual consent to each AI-related representation and warranty, including that the work retains a human-created work based on substantial and leading creative choices and expression by a human.

Documentation and Proof: “Show Your Work”

KOMCA also ties registration to verifiable proof of human involvement. The notice instructs creators to keep materials that support the creative process (e.g., digital audio workstation project files, revision histories, sheet music, and prompt logs), and to retain related revision history. KOMCA may request these materials, and applicants are expected to promptly provide supporting documentation when asked.

The notice also describes a review track for registrations that raise questions. KOMCA may conduct technical checks or use an internal deliberation process to verify AI use, test the truth of the disclosure, and/or assess whether the human contribution qualifies as substantial and leading.

Consequences of False Filings: Meaningful Financial and Contract Risk

KOMCA’s notice highlights direct consequences for false filings under its association rules and contract terms. Those measures include holding royalty payments, recovering improperly received amounts, imposing contractual penalties, and terminating the trust agreement. In other words, the disclosure and verification requirements are backed by remedies that can affect both cash flow and ongoing participation in KOMCA’s system.

New Requirements for Agents and Joint Works

KOMCA also tightened procedural rules for common filing structures. For agent-filed applications, KOMCA now expects written authority signed by the principal that expressly covers AI-related reporting, confirmation, representation, warranty, and pledge; nevertheless, the representations and warranties regarding the substantial and leading creative contribution by human and no prompt-only generation shall be made in the name of the principal. For joint works, a co-author may file and confirm the filer’s own contribution, and may report other co-authors’ contributions based on information received. KOMCA provides a seven-day objection window after notice.

Differences From U.S. Approach

On its face, KOMCA’s new rules closely align with guidelines set by the United States Copyright Office. AI-assisted works may be registered in the United States, however, the non-human elements must be disclosed and disclaimed, meaning that the scope of the copyright registration only covers the human-created elements of the work. An easy example is a book with human-created text and AI-created images. There, the original text would enjoy copyright protection while the images would not. It becomes much more nuanced as the human and AI created elements are less separable.

In the United States, there is currently no brightline rule as to how much human involvement is required to receive copyright protection. In South Korea, that threshold is now at least 51% of a work’s creative process.

This Policy Change Does Not (Yet) Modify Korean Law

Though KOMCA’s policy is a significant change, it does not alter South Korea’s existing copyright laws. In fact, South Korean lawmaker Kim Jae-won publicly criticized KOMCA’s policy change and highlighted that KOMCA does not possess the authority to unilaterally amend existing copyright law. In short, while KOMCA has decided to move forward with registration of certain AI-assisted works, the National Assembly has not yet amended its copyright law such that those registered works legally enjoy the copyright protection typically accorded by registration. 

Key Takeaways

KOMCA’s shift is practical, but unforgiving. If a music creator seeking copyright registration in South Korea used AI in the creation process, registration is now possible, but only if a human played a substantial, leading creative role and the application tells a detailed, accurate story about how the work was made.

For companies and rights holders, this makes documentation and disclosure a vital part of the creative and registration process. Build the record as the song is created. Keep the project files and revision history. Make sure credits, splits, and the registration narrative match the underlying materials. False or sloppy filings now carry real risk, including royalty holds, clawbacks, and possible termination of the trust agreement.

Practitioners and rights holders should continue to monitor ongoing discussions between KOMCA, the National Assembly, and the Ministry of Culture, Sports and Tourism regarding any changes to South Korea’s copyright laws.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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