What question did this study set out to answer?

To evaluate the copyrightability, authorship, and protection frameworks of AI-generated content across China, the United States, and the European Union.

August 20, 2026Cogent Social SciencesOpen Access

Can AI-generated content be protected by copyright? A comparative study of China, the United States, and the European Union

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To evaluate the copyrightability, authorship, and protection frameworks of AI-generated content across China, the United States, and the European Union.
Applied Zweigert and Kötz’s legal style framework across five core dimensions: historical background, legal reasoning modes, sources of law, institutional value orientation, and legal actor roles.
Conducted a comparative institutional analysis of judicial interpretations, administrative regulations, and legislative standards in the US, EU, and China.
Determined that while all three jurisdictions uphold the human authorship doctrine, the US enforces strict evidentiary thresholds for creative control, the EU focuses on doctrinal coherence, and China utilizes pragmatic, expansive judicial interpretations.
Found that China's flexible approach produces doctrinal ambiguity and unstable adjudicative standards, supporting a proposed three-stage reform involving mandatory labeling, revised registration rules, and dedicated legislative amendments.

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Implication

Comparative legal analysis reveals divergent copyright standards for AI-generated content across the US, EU, and China, highlighting the need for structured legal reforms in emerging AI markets.

Cite This Study

Wang et al. (2026) studied this question.

synapsesocial.com/papers/6a86b5978a91293e6a1cd104 https://doi.org/10.1080/23311886.2026.2717896

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Implication

Comparative legal analysis reveals divergent copyright standards for AI-generated content across the US, EU, and China, highlighting the need for structured legal reforms in emerging AI markets.

Can AI-generated content be protected by copyright? A comparative study of China, the United States, and the European Union

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Discussion

Implication

Cite This Study

Can AI-generated content be protected by copyright? A comparative study of China, the United States, and the European Union

Key Points

Discussion

Implication

Cite This Study

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