What does copyright protect?

How you get it

Automatic on creation of a work with individual character - no registration, no formalities, no deposit. There is no Swiss copyright register.

How long it lasts

70 years after the author's death for most works, but 50 years after death for computer programs.

The catch

With no register or deposit anywhere in Switzerland, authorship and creation date have to be proved by evidence you keep yourself.

Switzerland is not in the EU or the EEA: an EU trade mark or registered EU design does not cover Switzerland, and the unitary patent does not extend here.

Office: Swiss Federal Institute of Intellectual Property (IPI)

How you get it

Automatic on creation, with no formality. The DPMA states that registration in an official register is neither required nor possible.

How long it lasts

The life of the author plus 70 years.

The catch

German copyright cannot be bought. It is not transferable except on inheritance, so a business can only be granted rights of use - a contract purporting to assign it outright does not do so.

Germany is in the EU, so the national route sits alongside the EU trade mark and registered EU design at EUIPO, and the European patent at the EPO.

Office: German Patent and Trade Mark Office (DPMA)

How you get it

Automatic. Droit d'auteur arises from the mere fact of creation, with no registration, deposit or office. Voluntary deposits only evidence a date; they do not create the right.

How long it lasts

Economic rights run for the author's life plus 70 years. Moral rights are perpetual.

The catch

Employing an author transfers nothing - a contract of employment is expressly no derogation, so a written assignment is needed. Moral rights are perpetual, inalienable and imprescriptible. Software is the main exception.

France is in the EU, so the national route sits alongside the EU trade mark and registered EU design at EUIPO, and the European patent at the EPO.

Office: Institut national de la propriété industrielle (INPI)

How you get it

Automatic when the work is created, with no registration or other formality. The registration system that exists covers matters such as transfers, not the creation of the right.

How long it lasts

Life of the author plus 70 years. Works attributed to organisations and cinematographic works run 70 years from public disclosure.

The catch

The 2018 extension did not revive expired copyright. Only works still protected on 30 December 2018 gained the extra 20 years; anything already in the public domain in Japan stayed there.

Copyright is administered by the Agency for Cultural Affairs, not the JPO.

Office: Japan Patent Office (JPO)

How you get it

Automatic. Rights arise on creation with no registration and no filing - Poland has no copyright register, and the UPRP has no role in copyright at all.

How long it lasts

Seventy years from the end of the year of the author's death, or of the last surviving co-author for works of joint authorship.

The catch

An assignment of economic rights is void unless in writing, and transfers only the fields of exploitation the contract lists. Moral rights are unlimited in time and cannot be waived or sold.

Poland is in the EU but has not signed the Unified Patent Court Agreement, so a unitary patent has no effect in Poland.

Office: Patent Office of the Republic of Poland (UPRP)

How you get it

Automatic on creation, with no formality required. Unusually, Ukraine also offers voluntary state registration: UANIPIO issues a certificate. Registration is evidential only and does not create the right.

How long it lasts

The author's life plus 70 years, counted from 1 January of the year following the death of the author or the last surviving co-author.

The catch

The governing statute has been Law No. 2811-IX since 1 January 2023 - any guidance still citing the 1993 law is out of date. The new law also created sui generis rights, including 25 years for non-original computer-generated output.

The wartime suspension of IP time limits was cancelled with effect from 31 May 2025 and deadlines now run normally. Guidance published before then, saying deadlines are suspended, is out of date.

Office: Ukrainian National Office for Intellectual Property and Innovations (UANIPIO)

How you get it

Automatic on creation - there is no UK copyright register and nothing to apply for. Protection arises as soon as an original work is recorded in some material form.

How long it lasts

For literary, dramatic, musical and artistic works, 70 years from the end of the year the author dies. Other material differs: sound recordings 70 years from publication, broadcasts 50, published editions 25.

The catch

There is no official registration to point to, so you must be able to prove authorship and date from your own dated records. And 'life plus 70' does not apply across the board.

EU rights have not covered the UK since 1 January 2021. The UK remains a party to the European Patent Convention, which is separate from the EU.

Office: UK Intellectual Property Office (UKIPO)

How you get it

Automatic on creation, as soon as the work is fixed in a tangible form. Registration with the US Copyright Office is voluntary, but it is a precondition of suing over a US work.

How long it lasts

For works created since 1978, the life of the author plus 70 years; for works made for hire, 95 years from publication or 120 from creation, whichever ends first.

The catch

You need a registration in hand before filing suit over a US work, and statutory damages and attorneys' fees are only available if you registered before the infringement began, or within three months of publication.

Copyright is handled by the US Copyright Office, not the USPTO. The US has no separate design right: appearance is protected by a design patent.

Office: United States Patent and Trademark Office (USPTO)