Copyright

Protection arises without any formality and lasts for decades. It is the exceptions, not the rights, that change from country to country.

Illustration: Copyright ©

Why this page is on AffectionPlus

On a dating site you publish: a photo, the text of an ad, a poem, sometimes an image found elsewhere or taken by someone else. Copyright says what you may reuse, what you hand to the site by publishing, and what you can demand when your text or your picture turns up on another profile.

It is also the framework for the moderation work of a service like Affection.org, which has to handle reports of content reused without permission.

No formality — but you still need proof

In every country bound by the international conventions, protection arises on creation: no deposit, no notice, no symbol. The absence of a copyright notice therefore never means a work is free. Some systems, however, make registration a condition of suing at all, or of claiming statutory damages. Dating your files and keeping your working versions remains, everywhere, the most useful precaution.

Two philosophies of exceptions

Some systems set out a closed list of permitted purposes: quotation, criticism, news reporting, education, parody. Anything outside the list infringes, however reasonable it seems. Others apply an open-ended assessment, case by case, weighing the purpose of the use, how much was taken and the effect on the market for the work. The same content can therefore be entirely lawful in one country and an infringement in another: guidance written for one system does not transfer to the other.

Terms: the most common mistake

The usual term runs for several decades after the author's death, but the number varies noticeably between countries, and some have extended theirs recently. The practical consequence is routinely overlooked: a work in the public domain where you live may still be protected elsewhere. As soon as you publish online, you are exposed to the terms that apply wherever your readers are.

Crediting is never enough

Naming the author is an obligation where a use is permitted; it is not itself permission. Equally, an open licence is not an abandonment of rights: it imposes conditions — attribution, non-commercial use, share-alike — and breaching them removes the permission entirely. Read the licence, keep a dated copy, and check that it covers what you actually intend to do, including modification.

Facing a demand for payment

A demand is not a judgment. Check three things before paying: does the sender actually hold the rights, does the use fall within an applicable exception, and does the sum demanded resemble what a court would award? Never sign an undertaking not to repeat the use without having it reviewed: such undertakings are typically permanent and backed by a penalty.

The law country by country

The legal framework, the procedure, the time limits and the costs differ from one country to another. Each country below has a detailed page: governing texts, key facts, the actual procedure, costs, where to go and the traps to avoid.

Select a country to open its detailed page.

European framework

European Union

Two directives shape European copyright: the 2001 Information Society Directive and the 2019 Digital Single Market Directive, which made platforms responsible for what users upload.

Britain and Ireland

United Kingdom

Fair dealing, not fair use: only the listed purposes are permitted, and the list is closed.

Ireland

Fair dealing on the British model, with life plus seventy years and a 2019 reform broadening the exceptions.

North America

United States

Fair use is a flexible four-factor test — but registration is what gives a claim teeth.

Canada

The term moved to life plus seventy years at the end of 2022, and user-generated content has its own exception.

Australia and New Zealand

Australia

Fair dealing with five listed purposes, life plus seventy years, and no fair use despite repeated review recommendations.

New Zealand

Still life plus fifty years — New Zealand did not extend its term, because the trade-agreement provision requiring it was suspended.

South Asia

India

Life plus sixty years, a fair dealing clause with a long list of permitted acts, and statutory licences for broadcasting and cover versions.

Pakistan

The Copyright Ordinance 1962, with a term of life plus fifty years and registration through the IP Organisation.

South-East and East Asia

Singapore

A new Copyright Act came into force in 2021, adding a right of attribution and an open-ended factors test.

Malaysia

The Copyright Act 1987, with a voluntary notification system that provides prima facie evidence of ownership.

Philippines

The Intellectual Property Code, with a term of life plus fifty years and an active enforcement office.

Hong Kong

The 2022 amendment finally added parody, satire and quotation exceptions after more than a decade of debate.

Africa

South Africa

The Copyright Act 1978 still governs; a long-debated amendment bill introducing fair use has not come into force.

Nigeria

A brand-new Copyright Act in 2022 replaced the old law, extended the term to seventy years and added takedown procedures.

Kenya

The Copyright Act 2001, with an ISP takedown regime added in 2019 and an active Copyright Board.

Ghana

A seventy-year term, compulsory registration of folklore use, and a copyright office with formal registration.

Uganda

The Copyright and Neighbouring Rights Act 2006, with a fifty-year term and a registration register.

Zambia

The Copyright and Performance Rights Act, with a fifty-year term and a registrar-led enforcement structure.

The Caribbean

Jamaica

An unusually long term: ninety-five years after the author's death, the longest in the Caribbean.

Trinidad and Tobago

The Copyright Act protects works for life plus fifty years, with an active IP office and collective societies.

This topic is also covered for French-speaking countries · German-speaking countries.

Further reading

Links to official or reference sources. They open in a new tab.

Page checked in September 2026. The instruments cited can change: if in doubt, confirm with the official source given.

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