ECHA Will Propose EU-Wide Restrictions on Certain Hexavalent Chromium Substances
The European Commission (EC) requested that the European Chemicals Agency (ECHA) assess the risks posed by certain hexavalent chromium substances. ECHA announced on April 29, 2025, that it has concluded that a European Union (EU)-wide restriction for hexavalent chromium substances is justified because the substances “are among the most potent workplace carcinogens and pose a serious risk to workers’ health.” ECHA states that it expects to begin a six-month public consultation on a ban on hexavalent chromium substances, except in the following use categories when defined limits for worker exposure and environmental emissions are met:
Formulation of mixtures;
Electroplating on plastic substrate;
Electroplating on metal substrate;
Use of primers and other slurries;
Other surface treatment; and
Functional additives/process aids.
ECHA states that this restriction could replace the current authorization requirements under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation, ensuring that the risks associated with hexavalent chromium substances are effectively controlled once they are no longer subject to REACH authorization. ECHA notes that it included barium chromate in the scope of the restriction to avoid regrettable substitution.
ECHA states that stakeholders will have the opportunity to provide information during the six-month consultation, which is expected to start on June 18, 2025. ECHA plans to organize an online information session to explain the restriction process and help stakeholders take part in the consultation. ECHA’s Committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) will evaluate the restriction proposal and scientific evidence received during the consultation.
DFC to Play Critical Role in New U.S.-Ukraine Minerals Deal
On April 30, 2025, the United States and Ukraine signed an agreement (the “Agreement”) establishing a framework for the creation of the United States-Ukraine Reconstruction Investment Fund (the “Partnership”). The Partnership will be a joint natural resources and infrastructure investment fund between the U.S. and Ukraine. The U.S. International Development Finance Corporation (“DFC”) will play a critical role by serving as a limited partner of the Partnership alongside Ukraine’s State Organization Agency on Support of Public-Private Partnership. The Agreement does not identify the general partner.
The Agreement, by operation of its terms, provides the Partnership with preferential rights to participate in natural resources and public-private partnership projects and DFC (or DFC’s assignee) with preferential rights to negotiate offtake arrangements with respect to critical minerals projects. The U.S. and Ukraine are still in the process of finalizing the limited partnership agreement, which is expected to further clarify the operations of the Partnership. The key provisions of the Agreement, including capital contributions, investment rights, and offtake arrangements, are summarized below.
Capital Contributions
Ukraine will contribute to the Partnership 50% of the amounts received by Ukrainian governmental authorities for licenses, permits, and production sharing agreements relating to the exploration, extraction, and processing of “Natural Resources Relevant Assets.”[1]
The U.S. capital contribution to the Partnership will be increased by the assessed value of any new military assistance the U.S. provides to Ukraine in accordance with the limited partnership agreement.
The Agreement does not indicate how the Partnership will be initially capitalized.
Investment Opportunity Rights
Ukrainian governmental authorities responsible for licenses and permits relating to Natural Resources Relevant Assets and Ukrainian governmental authorities responsible for public-private partnership agreements and concessions must include in the relevant license, permit, or agreement, a provision requiring the recipient thereof to make “relevant investment information” available to the Partnership at any time the recipient is seeking to raise capital.
When the Partnership expresses formal interest in “participating” in one of these natural resources or infrastructure projects, the relevant Ukrainian governmental authority must include in the relevant license, permit, or agreement, provisions requiring the recipient thereof to grant to the Partnership a right similar to a right of first refusal. Specifically, the recipient must engage in good faith negotiations with the Partnership and refrain from granting to any third party materially more favorable economic terms than those offered to the Partnership.
The Agreement does not specify the precise nature of the Partnership’s participation in these projects and whether such participation may extend beyond direct investment.
Market-Based Offtake Rights
The Agreement provides a critical role for DFC, allowing DFC (or DFC’s assignee) to negotiate offtake rights in respect of projects involving Natural Resources Relevant Assets.
Specifically, the Agreement requires Ukrainian governmental authorities responsible for licenses or special permits relating to Natural Resources Relevant Assets to include in the relevant license or permit: (1) provisions allowing DFC (or DFC’s assignee) to negotiate offtake rights on market-based commercial terms, and (2) prohibiting the license or permit recipient from offering to any third party materially more favorable economic terms for offtake than those provided to DFC (or DFC’s assignee).
The Agreement provides a broad framework for U.S.-Ukraine cooperation in investing in critical minerals and infrastructure projects in Ukraine. DFC will play a critical role by serving as limited partner of the Partnership and by having the right to negotiate offtake arrangements for a wide array of natural resource projects in Ukraine. Further details regarding the limited partnership agreement and implementation of the Agreement are expected in the near future.
[1] The Agreement defines “Natural Resource Relevant Assets” as the sites, reserves, and deposits in the territory of Ukraine of aluminum, antimony, arsenic, barite, beryllium, bismuth, cerium, cesium, chromium, cobalt, copper, dysprosium, erbium, europium, fluorine, fluorspar, gadolinium, gallium, germanium, gold, graphite, hafnium, holmium, indium, iridium, lanthanum, lithium, lutetium, magnesium, manganese, neodymium, nickel, niobium, palladium, platinum, potash, praseodymium, rhodium, rubidium, ruthenium, samarium, scandium, tantalum, tellurium, terbium, thulium, tin, titanium, tungsten, uranium, vanadium, ytterbium, yttrium, zinc, zirconium, oil, natural gas (including liquified natural gas), and other minerals or hydrocarbons otherwise agreed by DFC and Ukraine’s State Organization Agency on Support of Public-Private Partnership.
China Issues the 2025 Intellectual Property Nation Building Promotion Plan To Accelerate the Construction of a Powerful Intellectual Property Country
On May 7, 2025, China’s National Intellectual Property Administration (CNIPA) published the 2025 Intellectual Property Nation Building Promotion Plan (2025年知识产权强国建设推进计划) authored by the Office of the Inter-ministerial Joint Conference on Building a Powerful National Intellectual Property Rights. The Plan lists the key tasks of 2025 to “accelerate the construction of a powerful intellectual property country.” Some of the key tasks including revising various laws and regulations, including the Trademark Law and issuing new guidelines, such as the Guidelines on Standard-Related Patent Policy.
A translation follows. The original text is available here (Chinese only).
This plan is formulated to implement the Outline for Building a Powerful Intellectual Property Country (2021-2035) (hereinafter referred to as the Outline) issued by the CPC Central Committee and the State Council and the National Intellectual Property Protection and Utilization Plan for the 14th Five-Year Plan (hereinafter referred to as the Plan) issued by the State Council, deepen the implementation of the strategy of building a powerful intellectual property country, accelerate the construction of a powerful intellectual property country, and clarify the key tasks for 2025.
This plan is formulated to implement the Outline for Building a Powerful Intellectual Property Country (2021-2035) (hereinafter referred to as the Outline) issued by the CPC Central Committee and the State Council and the National Intellectual Property Protection and Utilization Plan for the 14th Five-Year Plan (hereinafter referred to as the Plan) issued by the State Council, deepen the implementation of the strategy of building a powerful intellectual property country, accelerate the construction of a powerful intellectual property country, clarify the key tasks for 2025.
I. Improve the intellectual property system(I) Improve intellectual property laws, regulations and rules1. Accelerate the revision of the Trademark Law of the People’s Republic of China and the Regulations on the Protection of Integrated Circuit Layout Designs. (The National Intellectual Property Administration and the Ministry of Justice are responsible)2. Accelerate the revision of the Regulations on the Implementation of the Copyright Law of the People’s Republic of China and the Regulations on Collective Management of Copyrights, accelerate the revision of the Trial Measures for Voluntary Registration of Works, and promote the formulation of the Regulations on the Protection of Copyright of Folk Literature and Art Works. (The Central Propaganda Department and the Ministry of Justice are responsible)3. Promote the revision of the Regulations on the Protection of New Plant Varieties of the People’s Republic of China. (The Ministry of Agriculture and Rural Affairs, the National Forestry and Grassland Administration, and the Ministry of Justice are responsible)4. Study and demonstrate the Regulations on the Management of Access to Biological Genetic Resources and Benefit Sharing. (The Ministry of Ecology and Environment is responsible)5. Promote the revision of the Regulations of the People’s Republic of China on Customs Protection of Intellectual Property Rights. (General Administration of Customs is responsible)6. Promote the legislative process of the Regulations on the Protection of Traditional Chinese Medicine Knowledge. (State Administration of Traditional Chinese Medicine, National Health Commission, National Intellectual Property Administration is responsible)7. Promote the revision of the Regulations on National Defense Patents. (Equipment Development Department of the Central Military Commission, State Administration of Science, Technology and Industry for National Defense is responsible)8. Revise and issue the Regulations on the Protection of Trade Secrets. (State Administration for Market Regulation is responsible)9. Promote the revision of relevant judicial interpretations of the Trademark Law and Copyright Law. (Supreme People’s Court is responsible)
(II) Reform and improve major intellectual property policies10. Open up the entire chain of intellectual property creation, application, protection, management and service, and promote the establishment of an efficient comprehensive intellectual property management system. (National Intellectual Property Administration and relevant member units of the Joint Conference are responsible)11. Do a good job in the preparation of the “15th Five-Year Plan” intellectual property planning. (National Intellectual Property Administration and relevant member units of the Joint Conference are responsible)12. Promote the implementation of the “Reform Plan for the Division of Financial Powers and Expenditure Responsibilities between the Central and Local Governments in the Field of Intellectual Property”. (Ministry of Finance, National Intellectual Property Administration, Central Propaganda Department and other departments are responsible)13. Study and summarize the results of the World Bank’s business environment assessment, and issue and implement the “Opinions on Further Optimizing the Business Environment in the Intellectual Property Field”. (The National Intellectual Property Administration, the Central Propaganda Department, the National Development and Reform Commission, the Ministry of Education, the Ministry of Science and Technology, the Ministry of Industry and Information Technology, the State Administration for Market Regulation, and the Chinese Academy of Sciences are responsible)14. Formulate the “Guiding Opinions on Accelerating the High-quality Development of Copyright Work”. (The Central Propaganda Department is responsible)15. Formulate and issue the “Guidelines on Standard-related Patent Policy”. (The State Administration for Market Regulation and the National Intellectual Property Administration are responsible according to their respective duties)16. Formulate high-quality policy documents to promote the rapid and coordinated protection of intellectual property rights, study and issue guiding opinions on strengthening the arbitration of intellectual property disputes, and formulate guidelines for administrative adjudication and mediation of patent disputes. (The National Intellectual Property Administration and the Ministry of Justice are responsible)17. Study and formulate opinions on strengthening the protection of trade secrets. (The State Administration for Market Regulation is responsible)18. Formulate and issue the “Opinions on Strengthening the Intellectual Property Protection Work of Public Security Organs”. (The Ministry of Public Security is responsible)19. Accelerate the promotion of the “Measures for the Identification of Synthetic Content Generated by Artificial Intelligence” and the issuance of supporting mandatory national standards. (The Central Cyberspace Affairs Commission and the Ministry of Public Security are responsible)20. Issue and implement the “Implementation Plan for Major Biodiversity Conservation Projects (2025-2030)”. (Ministry of Ecology and Environment is responsible)
(III) Improve intellectual property rules in emerging and specific fields 21. Accelerate the research and construction of data intellectual property protection rules. (National Intellectual Property Administration and Ministry of Industry and Information Technology are responsible)22. Carry out the revision of the “Patent Examination Guidelines” and improve the patent examination standards for new fields and new formats. (National Intellectual Property Administration is responsible)23. Explore and improve the intellectual property protection rules for new fields and new formats such as big data, artificial intelligence, and blockchain. Improve the intellectual property protection rules in the Internet field. (The Central Propaganda Department, the Central Cyberspace Affairs Commission, the Supreme People’s Court, the Ministry of Industry and Information Technology, the State Administration for Market Regulation, and the National Intellectual Property Administration are responsible for their respective duties)24. Accelerate the improvement of judicial judgment rules for intellectual property rights in new technologies, new fields, and new formats, and judgment rules for e-commerce platform competition cases, and explore judicial rules for big data competition protection. (Supreme People’s Court is responsible)25. Support the free trade pilot zones to connect with international high-standard economic and trade rules, carry out pilot projects first, and replicate and promote them to a larger scale. (The Central Propaganda Department, the Ministry of Commerce, and the National Intellectual Property Administration are responsible according to their respective duties)26. Explore the copyright protection of traditional culture and traditional knowledge, and improve the copyright protection mechanism of sports events, variety shows, e-commerce platforms, and search engines. (The Central Propaganda Department is responsible)27. Actively explore the application of technologies such as artificial intelligence and blockchain in the confirmation, use, and protection of copyright in the fields of radio, television, and online audio-visual, and strengthen the development of blockchain application standards and related standards in the fields of radio, television, and online audio-visual. (The Ministry of Industry and Information Technology and the State Administration of Radio, Film, and Television are responsible according to their respective duties)28. Study and formulate guiding opinions on strengthening intellectual property work in the fields of culture and tourism. (The Ministry of Culture and Tourism, the Central Propaganda Department, the State Administration for Market Regulation, and the National Intellectual Property Administration are responsible)29. Continue to promote the construction of a database for the protection of traditional Chinese medicine knowledge and the publication of a list.(The State Administration of Traditional Chinese Medicine is responsible)
II. Strengthen intellectual property protection(I) Strengthen judicial protection of intellectual property30. Issue the “Opinions of the Supreme People’s Court on Serving and Safeguarding Scientific and Technological Innovation with High-quality Trials” and publish typical cases. (The Supreme People’s Court is responsible)31. Improve the national level intellectual property case appeal mechanism and strengthen the construction of a professional trial system. (The Supreme People’s Court is responsible)32. Adhere to strict protection, improve and fully implement the punitive compensation system for infringement. Strengthen the overall coordination of batch litigation and increase the crackdown on manufacturers and other sources of infringement. (The Supreme People’s Court is responsible)33. Formulate the “Interpretation on Several Issues Concerning the Application of Laws in Handling Criminal Cases of Intellectual Property Infringement”. (The Supreme People’s Court and the Supreme People’s Procuratorate are responsible)34. Deepen the comprehensive performance of intellectual property prosecution and further promote the professionalization of intellectual property prosecution. (The Supreme People’s Procuratorate is responsible)35. Formulate the “Management Measures for Technical Investigators of the Intellectual Property Procuratorate Office of the Supreme People’s Procuratorate” and improve the system of intellectual property prosecution professionals assisting in case handling. (The Supreme People’s Procuratorate is responsible)36. Regularly carry out supervision of malicious intellectual property litigation and publish typical cases of intellectual property prosecution protection. (The Supreme People’s Procuratorate is responsible)37. Organize and carry out special projects such as “Kunlun-2025” and “Anxin” to continue to crack down on intellectual property infringement crimes with high pressure. (The Ministry of Public Security is responsible)
(II) Strengthen administrative protection of intellectual property38. Carry out the “Sword Net 2025” special action to combat online infringement and piracy, and carry out special work on youth copyright protection and cinema film copyright protection. (The Central Propaganda Department, the Central Cyberspace Affairs Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, and the Ministry of Culture and Tourism are responsible for their respective duties)39. Carry out in-depth special law enforcement actions to “protect intellectual property rights”. Promote the pilot work of full-chain law enforcement of intellectual property rights. (The State Administration for Market Regulation is responsible)40. Organize and carry out market competition status assessments in key areas, and strengthen anti-monopoly supervision of standard essential patents, patent pools, etc. in key areas such as information and communications before, during, and after the whole chain. (The State Administration for Market Regulation is responsible)41. Deepen the national pilot work on trade secret protection innovation and form institutional results that can be replicated and promoted. Organize and carry out the third “Enterprise Trade Secret Protection Capacity Improvement Service Month” activity. (The State Administration for Market Regulation is responsible)42. Strengthen the construction of geographical indication review capabilities. Promote the construction of national geographical indication protection demonstration areas with high standards, and implement the geographical indication protection project in depth. (The State Intellectual Property Office is responsible)43. Continue to clean up and rectify infringement, counterfeiting, illegal and irregular information, urge websites and platforms to fulfill their main responsibilities, and improve the ability to review content related to intellectual property rights. (The Central Propaganda Department and the Central Cyberspace Affairs Commission are responsible according to their respective responsibilities)44. Improve the early resolution mechanism for pharmaceutical patent disputes. (The National Intellectual Property Administration and the State Food and Drug Administration are responsible according to their respective responsibilities)45. Continue to strengthen the protection of seed industry intellectual property rights, and severely crack down on counterfeiting, counterfeiting, infringement and other illegal acts. Strengthen the construction of technical support capabilities, improve the DNA molecular fingerprint database, and promote the implementation of variety ID card management. (The Ministry of Agriculture and Rural Affairs is responsible)46. Organize and carry out special actions for customs protection of intellectual property rights, and accelerate the construction of customs smart intellectual property business scenarios. (The General Administration of Customs is responsible)47. Continue to consolidate the results of software legalization work and carry out software legalization supervision work. (The Central Propaganda Department, the Ministry of Industry and Information Technology, the State Administration of State Administration and other units are responsible according to their respective responsibilities)48. Strengthen intellectual property protection in the field of intangible cultural heritage. (The Ministry of Culture and Tourism is responsible)
(III) Improve the pattern of coordinated protection of intellectual property rights49. Strengthen the connection between administrative law enforcement and judicial protection and cross-departmental and cross-regional law enforcement cooperation. (The Central Propaganda Department, the Supreme People’s Court, the Supreme People’s Procuratorate, the Ministry of Public Security, the Ministry of Agriculture and Rural Affairs, the Ministry of Culture and Tourism, the General Administration of Customs, the State Administration for Market Regulation, the National Intellectual Property Administration, and the National Forestry and Grassland Administration are responsible for their respective duties)50. Implement the intellectual property protection system construction project, guide the construction of intellectual property protection highlands, and optimize the layout of national intellectual property protection centers and rapid rights protection centers. (The National Intellectual Property Administration is responsible)51. Promote the construction of a national pilot project for the standardization of administrative adjudication of patent infringement disputes. (The National Intellectual Property Administration and the Ministry of Justice are responsible)52. Promote the establishment of an efficient foreign-related intellectual property protection work mechanism, improve the overseas dispute response guidance work system, and set up a number of overseas intellectual property dispute response guidance sub-centers. (The National Intellectual Property Administration, the Central Propaganda Department, the Ministry of Commerce, and the China Council for the Promotion of International Trade are responsible)53. Continue to promote the diversified resolution of intellectual property disputes, strengthen the construction of intellectual property dispute mediation organizations and arbitration institutions, and improve the docking mechanism between intellectual property administrative law enforcement and arbitration and mediation. (The Central Propaganda Department, the Supreme People’s Court, the Ministry of Justice, the National Intellectual Property Administration, and the China Council for the Promotion of International Trade are responsible according to their respective duties)54. Manage the transfer of intellectual property rights involving national security in accordance with the law, and study and formulate guidelines for the review of the transfer of patent rights in technology exports. (The Central Propaganda Department, the Ministry of Science and Technology, the Ministry of Agriculture and Rural Affairs, the Ministry of Commerce, the National Intellectual Property Administration, and the National Forestry and Grassland Administration are responsible according to their respective duties)55. Improve the credit supervision system in the field of intellectual property rights in accordance with the law, and strengthen the collection and sharing of relevant credit information in the field of intellectual property rights. (The Central Propaganda Department, the National Development and Reform Commission, the People’s Bank of China, the State Administration for Market Regulation, and the National Intellectual Property Administration are responsible according to their respective duties)56. Promote the political and legal organs to crack down on crimes involving intellectual property protection in accordance with the law, and investigate and deal with infringements in accordance with the law. (The Central Political and Legal Affairs Commission is responsible)
III. Improve the operation mechanism of the intellectual property market(I) Improve the quality of intellectual property creation57. Promote the improvement of the quality of patent applications, improve the quality-oriented indicator system and evaluation system, and establish a pre-patent application evaluation system with industrialization prospect analysis as the core. (The Ministry of Education, the Ministry of Science and Technology, the National Intellectual Property Administration, and the Chinese Academy of Sciences are responsible according to their respective duties)58. Continue to improve the quality and efficiency of patent and trademark examinations, optimize resource allocation, meet the examination needs of key areas, and steadily promote the application of multimodal large model technology in examination work. Deepen the reform of the trademark examination and approval mechanism, and launch a new generation of trademark examination system. (The State Intellectual Property Office is responsible)59. Study and promote the construction of a unified national copyright registration mechanism for works, standardize the standards and processes for copyright registration and examination of works, enhance the informatization level of copyright registration of works, and continuously improve the quality of copyright registration of works. (The Central Propaganda Department is responsible)60. Improve the work system of intellectual property rights to support key core technology research and development, deepen the patent navigation in key areas, and strengthen the creation and layout of high-value patents. (The State Intellectual Property Office, the Ministry of Education, the Ministry of Science and Technology, the Ministry of Industry and Information Technology, the State-owned Assets Supervision and Administration Commission of the State Council, and the Chinese Academy of Sciences are responsible)61. Study and improve the supporting system for intellectual property management of national science and technology plan projects, and do a good job in intellectual property management of national key R&D plan projects. (The Ministry of Science and Technology and the competent departments of each project are responsible according to their respective responsibilities)62. Optimize the acceptance and examination process of new plant variety rights, improve the online application and examination system, and improve the efficiency of authorization. (The Ministry of Agriculture and Rural Affairs and the National Forestry and Grassland Administration are responsible according to their respective responsibilities)
(II) Strengthen the transformation and application of intellectual property rights63. Deeply implement the special action of patent transformation and application. On the basis of the previous review and inventory of existing patents, strengthen data sharing among departments, strengthen the precise connection between supply and demand, continue to activate the existing stock, optimize the incremental stock, promote the strengthening and efficiency of intellectual property rights in key industries, summarize experience and practices, and form a long-term mechanism. (The Ministry of Education, the Ministry of Science and Technology, the Ministry of Industry and Information Technology, the Ministry of Agriculture and Rural Affairs, the National Health Commission, the State-owned Assets Supervision and Administration Commission of the State Council, the National Intellectual Property Administration, and the Chinese Academy of Sciences are responsible for their respective duties)64. Vigorously cultivate and develop patent-intensive industries and copyright industries. Carry out the accounting and publication of the added value of patent-intensive industries. Conduct a survey on the contribution of copyright industries to the national economy. (The National Bureau of Statistics, the National Intellectual Property Administration, and the Central Propaganda Department are responsible for their respective duties)65. Promote the construction of key industry intellectual property innovation consortiums, key field patent pools, and intellectual property operation centers in an integrated manner, and create a model for patent industrialization to promote the growth of small and medium-sized enterprises. Accelerate the high-quality development of the science and technology service industry, cultivate and expand high-level science and technology service institutions, create a national unified technology transaction service platform, accelerate the transformation and industrialization of scientific and technological achievements, and help small and medium-sized enterprises innovate and develop. (National Intellectual Property Administration and Ministry of Industry and Information Technology are responsible)66. Deepen the reform of intellectual property rights distribution, study and promote the pilot experience of the reform of empowering the rights of scientific and technological achievements in official positions and the reform of separate asset management, and promote the establishment of a due diligence exemption mechanism. (Ministry of Education, Ministry of Science and Technology, Ministry of Finance, State-owned Assets Supervision and Administration Commission of the State Council, National Intellectual Property Administration, and Chinese Academy of Sciences are responsible according to their respective duties)67. Promote the implementation of the declaration system for the formation of intellectual property rights in financially funded scientific research projects. (National Intellectual Property Administration, Central Propaganda Department, Ministry of Science and Technology, Ministry of Finance, National Natural Science Foundation of China, State Administration of Science, Technology and Industry for National Defense, and Equipment Development Department of the Central Military Commission are responsible)68. Promote the construction of a “center + node” university scientific and technological achievement transformation system with the national university regional technology transfer and transformation center as the hub and the national university science and technology park as the node, build a “full chain” public transformation platform, and strengthen the construction of intellectual property professional service teams. (Ministry of Education is responsible)69. Deepen the implementation of the patent open licensing system and promote more scientific and technological achievements from laboratories to the industrial chain. (National Intellectual Property Administration, Ministry of Education, Ministry of Industry and Information Technology, and Chinese Academy of Sciences are responsible)70. Dynamically optimize the patent ranking index system of central enterprises, and guide central enterprises to strengthen the creation, application and protection of high-value patents. Encourage central enterprises to strengthen industry-university-research cooperation, and cultivate high-value patents through innovation alliances and other means. (SASAC and the State Intellectual Property Office are responsible)71. Vigorously implement the trademark brand strategy, and deepen the action of geographical indications to help rural revitalization. (The State Intellectual Property Office is responsible)72. Promote the quality grading of agricultural products with geographical indications and promote quality improvement. (The Ministry of Agriculture and Rural Affairs is responsible)73. Continue to carry out pilot work on the protection and promotion of folk art copyrights. (The Central Propaganda Department is responsible)74. Accelerate the implementation of the substantial derivative variety system, formulate guidelines for the determination of substantial derivative varieties and the first batch of substantial derivative variety system catalogs, and preliminarily select a batch of appraisal institutions. (The Ministry of Agriculture and Rural Affairs and the National Forestry and Grassland Administration are responsible according to the division of responsibilities)75. Continue to promote the implementation of intellectual property standards by units affiliated to the Chinese Academy of Sciences. (The Chinese Academy of Sciences is responsible)76. Promote the construction of intellectual property service export bases. (The Central Propaganda Department, the Ministry of Commerce, and the National Intellectual Property Administration are responsible for their respective duties)
(III) Promote the market-oriented operation of intellectual property77. Actively and steadily develop intellectual property finance, give full play to the role of the national intellectual property pledge information platform, and coordinate the promotion of intellectual property pledge financing, securitization, and insurance. (The Central Propaganda Department, the National Development and Reform Commission, the People’s Bank of China, the Financial Regulatory Commission, the China Securities Regulatory Commission, and the National Intellectual Property Administration are responsible for their respective duties)78. Gradually expand the internal evaluation pilot of intellectual property pledge financing and improve the level of convenience for intellectual property pledge registration. Guide local governments to increase support for intellectual property financing guarantees. (The Central Propaganda Department, the People’s Bank of China, the Financial Regulatory Commission, and the National Intellectual Property Administration are responsible for their respective duties)79. Encourage insurance companies to optimize intellectual property insurance products and services and focus on developing insurance products related to international trade intellectual property protection. (The Central Propaganda Department, the Financial Regulatory Commission, and the National Intellectual Property Administration are responsible for their respective duties)80. Improve the supervision system for intellectual property asset securitization business, guide exchanges to innovate intellectual property asset securitization models, and encourage technology-based enterprises to carry out financing through intellectual property asset securitization. (The China Securities Regulatory Commission, the Central Propaganda Department, and the National Intellectual Property Administration are responsible)81. Promote the benefit of new varieties of forest and grassland plants to farmers and pledge financing of variety rights. (National Forestry and Grassland Administration, People’s Bank of China)
IV. Improve the efficiency of intellectual property services(I) Strengthen the supply of intellectual property public services82. Deeply implement the intellectual property public service benefit project, and solidly promote the pilot of intellectual property public service standardization. Establish and improve the “good and bad review” system for intellectual property government services. (National Intellectual Property Administration)83. Promote the establishment of an intellectual property public service work mechanism to support the key core technology research in key areas. (National Intellectual Property Administration)84. Study and formulate the “Guidelines for the Analysis and Utilization of Intellectual Property Information”. (National Intellectual Property Administration)85. Launch the national intellectual property protection information platform, explore the construction of a national integrated intellectual property digital public service platform, support the construction of an independent and controllable intellectual property database, and expand the open sharing of basic data. (National Intellectual Property Administration)86. Promote the connection and application of intellectual property-related public service platforms with the national network identity authentication public service platform to strengthen user information security. (National Intellectual Property Administration, Ministry of Public Security)87. Optimize the service application scenarios of grassroots organizations of the patent information resource system and empower grassroots intellectual property services. (China Association for Science and Technology is responsible)
(II) Promote the development of intellectual property services88. Comprehensively strengthen the supervision of the intellectual property agency industry, strengthen the comprehensive governance of the industry, and improve the professional capabilities and level of intellectual property service institutions. (National Intellectual Property Administration is responsible)89. Accelerate the formation of a standard system for the intellectual property service industry, promote the construction of intellectual property service industry clusters, and establish a regional cooperation and assistance mechanism for the intellectual property service industry. (National Intellectual Property Administration is responsible)90. Promote the use of the “Patent and Trademark Agency Service Government Procurement Demand Standard (Trial)”. (Ministry of Finance and National Intellectual Property Administration are responsible)91. Strengthen and improve the supervision of copyright collective management organizations, guide copyright collective management organizations to expand their business, and encourage copyright collective management organizations to cooperate with relevant industry associations. Promote the standardization of certification work by overseas copyright certification agencies. (Central Propaganda Department is responsible)
V. Create a good intellectual property humanistic and social environment(I) Vigorously advocate intellectual property cultural concepts92. Organize and hold large-scale activities such as World Intellectual Property Day, National Intellectual Property Promotion Week, China International Copyright Expo, International Copyright Forum, and China Brand Day. We will do a good job in building a strong country in intellectual property rights and publicize the achievements of intellectual property development during the 14th Five-Year Plan period. We will strengthen external publicity of intellectual property rights through platforms such as the China International Import Expo and the China International Fair for Trade in Services, and tell the story of Chinese intellectual property rights well. (The Central Propaganda Department, the Central Cyberspace Affairs Commission, the Ministry of Foreign Affairs, the National Development and Reform Commission, the Ministry of Commerce, the State-owned Assets Supervision and Administration Commission of the State Council, the State Administration for Market Regulation, the State Administration of Radio, Film and Television, the National Intellectual Property Administration, and the China Council for the Promotion of International Trade are responsible for their respective duties)93. Organize activities related to the 40th anniversary of the implementation of the Patent Law of the People’s Republic of China. (The National Intellectual Property Administration is responsible)94. Promote the implementation of the “whoever enforces the law shall popularize the law” responsibility system in all regions and relevant departments, and strengthen the publicity of intellectual property law. Strengthen the use of new media and new technologies, and actively carry out popularization of law through cases in China’s popularization of law “one network, two microblogs, and one terminal”. (The Ministry of Justice is responsible)95. Make full use of important time nodes such as the National Science Popularization Month, the National Science and Technology Activity Week, and the National Intellectual Property Promotion Week to carry out intellectual property science popularization activities. Relying on the China Science Popularization Information Platform, strengthen the all-media dissemination of intellectual property science popularization resources. (The Ministry of Science and Technology and the China Association for Science and Technology are responsible)96. Carry out a series of publicity activities on customs protection of intellectual property rights, and release the status of intellectual property protection in China’s customs in 2024. Optimize the functional layout of the customs intellectual property protection exhibition center, and create an “Internet +” intellectual property customs protection publicity position. (The General Administration of Customs is responsible)
(II) Lay a solid foundation for the development of intellectual property rights97. Increase the training of intellectual property administrative personnel and build a high-quality professional cadre talent team. (The Central Propaganda Department and the National Intellectual Property Administration are responsible according to their respective duties)98. Deepen the implementation of the professional and technical personnel knowledge update project, and increase the training of high-level professional and technical personnel in the field of intellectual property rights. Improve the intellectual property talent evaluation system and the professional title evaluation method for intellectual property professionals. (The Central Propaganda Department, the Ministry of Human Resources and Social Security, and the National Intellectual Property Administration are responsible according to their respective duties)99. Vigorously cultivate international talents such as foreign-related intellectual property lawyers. (The Ministry of Justice and the National Intellectual Property Administration are responsible according to their respective duties)100. Promote the construction of intellectual property professional degrees and related disciplines in colleges and universities, do a good job in the construction of the co-construction of intellectual property colleges, and strengthen the collaborative training of intellectual property talents. (The Ministry of Education, the National Intellectual Property Administration, and the Central Propaganda Department are responsible according to their respective duties)101. Strengthen the construction of technical managers, expand the scale of training, improve the quality of training, and promote the transformation and industrialization of scientific and technological achievements. (Ministry of Industry and Information Technology, Ministry of Science and Technology)102. Promote the construction of intellectual property think tanks and strengthen research on major theoretical and practical issues. (Central Propaganda Department, Supreme People’s Court, Ministry of Education, National Intellectual Property Administration, Chinese Academy of Sciences are responsible according to their respective duties)
VI. Deeply participate in global intellectual property governance103. Carry out consultations in various fields under the framework of the World Intellectual Property Organization, promote the formulation of international rules for intellectual property in new fields and new formats, and promote the inclusion of Chinese language consultations in the Madrid system. (National Intellectual Property Administration, Central Propaganda Department, Ministry of Foreign Affairs, Ministry of Justice)104. Organize the 2025 series of cooperation directors’ meetings of the five intellectual property offices of China, the United States, Europe, Japan and South Korea, and jointly hold related activities for the 40th anniversary of cooperation between the China-EU Intellectual Property Offices. (National Intellectual Property Administration)105. Actively participate in discussions on relevant issues under multilateral platforms such as the WTO and APEC, deepen bilateral exchanges and cooperation on intellectual property rights with trading partners such as the EU, Japan, Russia, and Switzerland in the economic and trade fields, and actively promote negotiations on intellectual property rights issues in free trade agreements and the entry into force of the second batch of product lists of the China-EU Geographical Indications Agreement. (Ministry of Commerce, Central Propaganda Department, and National Intellectual Property Administration are responsible)106. Promote the deepening and implementation of the “Belt and Road” intellectual property cooperation, and implement the results of the third “Belt and Road” intellectual property high-level meeting. Hold the 2025 China-ASEAN Intellectual Property Office Directors’ Meeting, promote the improvement of the BRICS intellectual property cooperation mechanism, and support the holding of the second China-Central Asia Intellectual Property Office Directors’ Meeting. (National Intellectual Property Administration, Central Propaganda Department, and Ministry of Foreign Affairs are responsible)107. Promote substantive consultations on international treaties such as the Treaty on the Protection of Broadcasting Organizations and the Treaty on the Protection of Traditional Cultural Expressions. Do a good job in the implementation of key international copyright treaties such as the Beijing Treaty on Audiovisual Performances and the Marrakesh Treaty. (Central Propaganda Department and State Administration of Radio, Film and Television are responsible according to their respective duties)108. Seriously implement the International Convention for the Protection of New Varieties of Plants, deepen multilateral and bilateral technical exchanges and cooperation, and participate in the formulation of relevant international standards. (The Ministry of Agriculture and Rural Affairs, the National Intellectual Property Administration, and the National Forestry and Grassland Administration are responsible for their respective duties)109. Relying on the multilateral and bilateral law enforcement cooperation mechanism, strengthen communication and cooperation with foreign law enforcement departments around key transnational infringement and counterfeiting criminal cases. Give full play to the main channel role of Interpol and actively participate in joint law enforcement actions organized by it. (The Ministry of Public Security is responsible)110. Actively participate in international intellectual property affairs under multilateral frameworks such as the World Customs Organization, and promote the establishment of multilateral and regional cooperation mechanisms. (The General Administration of Customs is responsible)111. Strengthen the construction of overseas intellectual property information service platforms, release early warning information in a timely manner, provide services to enterprises in key areas and key links, and do a good job in risk investigation and rights protection guidance. (The Central Propaganda Department, the Ministry of Commerce, the National Intellectual Property Administration, and the China Council for the Promotion of International Trade are responsible for their respective duties)112. Carry out the establishment of training projects in the field of intellectual property and promote human resources development cooperation in the field of intellectual property. (The Central Propaganda Department, the National Intellectual Property Administration, and the National International Development Cooperation Agency are responsible for their respective duties)113. Prepare for the 2025 Global Business Rule of Law Conference and strengthen exchanges and cooperation with non-governmental international intellectual property organizations. (China Council for the Promotion of International Trade is responsible)
VII. Strengthen organizational guarantees114. Carry out a five-year summary and evaluation of the Outline and the Plan, strengthen statistical monitoring of indicator data, and supervise and inspect the implementation of work tasks. (Joint Conference Office and member units of the Joint Conference are responsible)115. Collect and promote the fourth batch of typical cases for the construction of a strong intellectual property country. (Joint Conference Office is responsible)116. Give full play to the role of the Expert Advisory Committee for the Construction of a Strong Intellectual Property Country and the National Intellectual Property Strategy Implementation Research Base, and strengthen policy consultation and research support. (Joint Conference Office is responsible)117. Implement tax and fee support policies to support scientific and technological innovation and encourage enterprises to increase their own investment in scientific and technological innovation. (The Ministry of Finance and the State Administration of Taxation are responsible according to their respective duties)118. Prepare and publish the annual development report on the construction of a strong intellectual property country. (Joint Conference Office is responsible)In the above-mentioned division of labor, if multiple departments are responsible, the department listed first is the leading department, and the others are participating departments.
European Union Adopts 16th Package of Sanctions Against Russia
In a bid to further increase the pressure on Russia, the Council of the European Union has adopted additional measures which have been introduced in its 16th sanctions package. The new measures amending the framework Council Regulation (EU) 833/2014 are found and included in Council Regulation (EU) 2025/395 (EU’s 16th Package). They target systemically important sectors of the Russian economy, including energy, trade, transport, infrastructure and financial services.
Additional Listings
An additional 48 individuals and 35 entities have been targeted by asset freezes and travel bans. The EU’s 16th Package adds new criteria for listing individuals and entities that are part of support or benefit from Russia’s military-industrial complex. This is in addition to any entities or individuals who are active in sanctions circumvention, maritime or Russian crypto assets exchanges.
Anti-Circumvention Measures
An additional 74 vessels, bringing the total number of listed vessels to 153, have been added. These vessels are part of the shadow fleet or contribute to Russia’s energy revenues.
Trade Measures
Ban on Primary Aluminium Imports
The EU’s 16th Package also adopts further restrictions on the trade of goods and services. An aluminium import ban on EU imports of primary aluminium from Russia has been included. The exception to this is that it includes a “phase-in period” permitting the import of 275,000 tons over a 12-month period.
Export Bans
Export restrictions have been added which target 53 new companies, which include 34 companies outside of Russia and which support Russia’s military-industrial complex.
Dual-use export restrictions have been extended to additional items in order to cut Russia’s access to key technologies, including the following:
Dual-use chemical precursors to produce chloropicrin and other riot control agents used as chemical weapons by Russia in violation of the Chemical Weapons Convention.
Software related to computer numerical control machine tools used to manufacture weapons and video game controllers used by the Russian army to pilot drones on the battlefield.
Chromium ores and compounds due to their military applications.
Additional export restrictions on industrial goods, such as steel products, fireworks and certain minerals and chemicals, have been included.
Energy Measures
The EU’s 16th Package prohibits temporary storage or the placement under free zone procedures of Russian crude oil or petroleum products in EU ports, which was, until now, allowed if the oil complied with the price cap and went to a third country. This prohibition will inflict additional costs on the transport of Russian oil.
The package extends the prohibition to provide goods, technology and services for the completion of Russian liquefied natural gas projects to also crude oil projects in Russia, such as the Vostok oil project.
The package extends the existing software ban to restrict the export, supply or provision of oil and gas exploration software, which includes drilling processes, geological inspections and reservoir calculations, to Russia.
Infrastructure Measures
With immediate effect, a full transaction ban on specific Russian infrastructures—ports and airports which are believed to have been used to transport combat-related goods and technology or to circumvent the oil price cap by transporting Russian crude oil via ships in the shadow fleet—have been included in this latest package as they contribute to Russia’s military efforts.
The restrictions are broadly drafted and will apply to any transactions with relevant ports and airports (as listed in Annex XLVII of the EU’s 16th Package), even if there is no direct transaction with the port authorities themselves.
Transport Measures
One of the most notable changes under Article 5ae of the EU’s 16th Package is the imposition of a full flight ban which provides for the possibility to list any third-country airline operating domestic flights within Russia or supplying, selling, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to a Russia air carrier or for flights within Russia.
If listed in Annex XLVI of the EU’s 16th Package, these air carriers, as well as any entity owned or controlled by them, will not be allowed to land in, take off from or fly over EU territory.
The flight ban will not apply to the following:
• In the case of an emergency landing or an emerging overflight.• If such landing, take-off or overflight is required for humanitarian purposes.
Financial Measures
An additional 13 Russian banks and three non-Russian banks, namely Bank BelVEB, Belgazprombank and VTB Bank (PJSC) Shanghai Branch (due to their use of the system for Transfer of Financial Messages of the Central Bank of Russia), have been either disconnected from the Society for Worldwide Interbank Financial Telecommunication international payment system or subjected to a transaction ban, intensifying financial isolation of Russia.
The European Union has also extended a transaction ban to allow it to target financial institutions and crypto asset providers circumventing the oil price cap so as to further isolate Russia’s financial network.
Measures Against Disinformation
To combat media manipulation and distortion of events, further restrictive measures have been placed on broadcasting activities. Eight additional media outlets, namely EADaily, Fondsk, Lenta, NewsFront, RuBaltic, SouthFront, Strategic Culture Foundation and Krasnaya Zvezda, have had broadcasting suspended because they are under the permanent control of Russian leadership and participate in spreading misinformation and propaganda.
Concluding Remarks
These increased enforcement efforts and highlighted sanctions are not just symbolic but impactful. As the European Union strengthens its sanctions framework and expands enforcement efforts, businesses must proactively assess their compliance strategies to mitigate legal and operational risks.
From Blocks to Rights: Privacy and Blockchain in the Eyes of the EU data Protection Authorities
On April 14, 2025, the European Data Protection Board (EDPB) released guidelines detailing how to process personal data using blockchain technologies in compliance with the General Data Protection Regulation (GDPR) (Guidelines 02/2025 on processing of personal data through blockchain technologies). These guidelines highlight certain privacy challenges and provide practical recommendations.
Challenges Under the GDPR
Blockchain’s immutability conflicts with rights to data rectification and deletion (Articles 16 and 17 GDPR). Its decentralized nature makes it difficult to comply with GDPR principles like data minimization, storage limitation (Article 5) and data protection by design (Article 25). International data transfers are also complicated, prompting the EDPB to recommend using standard contractual clauses for node participation to ensure Chapter V compliance.
Key Recommendations for Organizations
In order to minimize risks and ensure GDPR compliant data processing when using blockchain, the EDPB establishes certain rules for organizations to follow.
Roles and Responsibilities
Roles must be clearly defined based on service nature, governance and relationships. The EDPB makes a special mention of nodes in public permissionless blockchains. Nodes in public blockchains may be considered data controllers. A legal entity (e.g., a consortium) is encouraged when nodes jointly determine processing purposes.
Technical and Organizational Measures
Organizations should assess:
Whether personal data will be stored
If so, why is the blockchain needed
The type of blockchain to be used (public only if necessary)
The adequate technical safeguards to be implemented
Public blockchains should be avoided unless essential. Personal data should only be identifiable if necessary and justified via a Data Protection Impact Assessment (DPIA). The techniques the EDPB suggests limiting the identifiability of the personal data include:
Encryption – Protects data, but remains personal under GDPR.
Hashing – Offers security, but risks remain if keys are compromised.
Cryptographic commitments – Securely obscure data when original inputs are deleted.
GDPR Principles and Data Subject Rights
Deletion and objection – Due to blockchain’s permanence, erasure may require deleting parts of the chain or anonymizing data. Off-chain storage of personal data is preferred.
Data retention – If data isn’t needed for the blockchain’s full life, it shouldn’t be stored on-chain unless anonymized.
Security – Suggested safeguards include emergency protocols, breach notifications and protections against 51% attacks and rogue participants.
Rectification – If rectification requires deletion, standard erasure methods apply. Otherwise, new transactions must correct prior data without altering old entries.
Automated decisions – Controllers must meet Article 22 GDPR requirements even if a smart contract has executed.
Next Steps
Public consultation is open until June 9, 2025. The final version is expected to remain largely consistent with the draft, offering essential guidance for GDPR-compliant blockchain use.
This article was co-authored by Damian Perez-Taboada
The European Commission’s Guidance on Prohibited AI Practices: Unraveling the AI Act
The European Commission published its long-awaited Guidelines on Prohibited AI Practices (CGPAIP) on February 4, 2025, two days after the AI Act’s articles on prohibited practices became applicable.
The good news is that in clarifying these prohibited practices (and those excluded from its material scope), the CGPAIP also addresses other more general aspects of the AI Act, which comes to provide much-needed legal certainty to all authorities, providers and deployers of AI systems/models in navigating the regulation.
It refines the scope of general concepts (such as “placing on the market”, “putting into service”, “provider” or ” deployer”) and exclusions from the scope of the AI Act, provides a definition of others not expressly included in the AI Act (such as “use”, “national security”, “purposely manipulative techniques” or “deceptive techniques”), as well as takes a position on the allocation of responsibilities of providers and deployers using a proportionate approach (establishing that these responsibilities should be assumed by whoever is best positioned in the value chain).
It also comments on the interplay of the AI Act with other EU laws, explaining that while the AI Act applies as lex specialis to other primary or secondary EU laws with respect to the regulation of AI systems, such as the General Data Protection Regulation (GDPR) or EU consumer protection and safety legislation, it is still possible that practices permitted under the AI Act are prohibited under those other laws. In other words, it confirms that the AI Act and these other EU laws complement each other.
However, this complementarity is likely to pose the greatest challenges to both providers and deployers of the systems. For example, while the European Data Protection Board (EDPB) has already clarified in its Opinion 28/2024 on certain data protection aspects related to the processing of personal data in the context of AI models (adopted in December 2024) that the “intended” purposes of AI models at the deployment stage must be taken into account when assessing whether the processing of personal data for the training of said AI models can be based on the legitimate interest of the providers and/or future deployers. The European Commission clarifies in Section 2.5.3 of the CGPAIP that the AI Act does not apply to research, testing (except in the real world) or development activities related to AI systems, or AI models before they are placed on the market or put into service (i.e. during the training stage). Similarly, the CGPAIP provides some examples of exclusions from prohibited practices (i.e., permitted practices) that are unlikely to find a lawful basis in the legitimate interests of providers and/or future users of the AI system.
The prohibited practices:
Subliminal, purposefully manipulative or deceptive techniques (Article 5(1)(a) and Article 5(1)(b) AI Act)This prohibited practice refers to subliminal, purposefully manipulative or deceptive techniques that are significantly harmful and materially influence the behavior of natural persons or group(s) of persons, or exploit vulnerabilities due to age, disability or a specific socio-economic situation.
The European Commission provides examples of subliminal techniques (visual and auditory subliminal messages, subvisual and subaudible queueing, embedded images, misdirection and temporal manipulation), as well as explains that the rapid development of related technologies, such as brain-computer interfaces or virtual reality, increases the risk of sophisticated subliminal manipulation.
When referring to purposefully manipulative techniques (to exploit cognitive biases, psychological vulnerabilities or other factors that make individuals or groups of individuals susceptible to influence), it clarifies that for the practice to be prohibited, either the provider or the deployer of the AI system must intend to cause significant (physical, psychological or financial/ economic) harm. While this is consistent with the cumulative nature of the elements contained in Article 5(1)(a) of the AI Act for the practice to be prohibited, it could be read as an indication that manipulation of an individual (beyond consciousness) where it is not intended to cause harm (for example, for the benefit of the end user or to be able to offer a better service) is permitted. The CGPAIP refers here to the concept of “lawful persuasion”, which operates within the bounds of transparency and respect for individual autonomy.
With respect to deceptive techniques, it explains that the obligation of the provider to label “deep fakes” and certain AI-generated text publications on matters of public interest, or the obligation of the provider to design the AI system in a way that allows individuals to understand that they are interacting with an AI system (Article 50(4) AI Act) are in addition to this prohibited practice, which has a much more limited scope.
In connection with the interplay of this prohibition with other regulations, in particular, with the DSA, the European Commission recognizes that dark patterns are an example of manipulative or deceptive technique when they are likely to cause significant harm.
It also provides that there should be a plausible/reasonably likely causal link between the potential material distortion of the behavior (significant reduction in the ability to make informed and autonomous decisions) and the subliminal, purposefully manipulative or deceptive technique deployed by the AI system.
Social scoring (Article 5(1)(c) AI Act)The CGPAIP defines social scoring as the evaluation or classification of individuals based on their social behavior, or personal or personality characteristics over a certain period of time, clarifying that a simple classification of people on said basis would trigger this prohibition and that the concept evaluation is inclusive of “profiling” (in particular to analyze and/or make predictions on interests or behaviors), that leads to detrimental or unfavorable treatment in unrelated social contexts, and/or unjustified or disproportionate treatment.
Concerning the requirement that it leads to detrimental or unfavorable treatment, it is established that such harm may be caused by the system in combination with other human assessments, but that at the same time, the AI system must play a relevant role in the assessment. It also provides that the practice is prohibited even if the detrimental or unfavorable treatment is produced by an organization different from the one that uses the score.
The European Commission states, however, that AI systems can lawfully generate social scores if they are used for a specific purpose within the original context of the data collection and provided that any negative consequences from the score are justified and proportionate to the severity of the social behavior.
Individual Risk Assessment and Prediction of Criminal Offences (Article 5(1)(d) AI Act)When interpreting this prohibited practice, the European Commission outlines that crime prediction and risk assessment practices as such are not outlawed, but only when the prediction of a natural person committing a crime is made solely on the basis of a profiling of said individual, or on assessing their personality traits and characteristics. In order to avoid circumvention of the prohibition and ensure its effectiveness, any other elements being taken into account in the risk assessment will have to be real, substantial and meaningful for them to be able to justify the conclusion that the prohibition does not apply (excluding therefore AI systems to support the human assessment based on objective and verifiable facts directly linked to a criminal activity, in particular when there is human intervention).
Untargeted Scraping of Facial Images (Article 5(1)(e) AI Act)The European Commission clarifies that the purpose of this prohibited practice is the creation or enhancement of facial recognition databases (a temporary, centralized or decentralized database that allows a human face from a digital image or video frame to be matched against a database of faces) using images obtained from the Internet or CCTV footage, and that it does not apply to any scraping AI system tool that can be used to create or enhance a facial recognition database, but only to untargeted scraping tools.
The prohibition does not apply to the untargeted scraping of biometric data other than facial images, or even if it is a database that is not used for the recognition of persons. For example to generate images of fictitious persons and clarifies that the use of databases created prior to the entry into force of the AI Act, which are not further expanded by AI-enabled untargeted scraping, must comply with applicable EU data protection rules.
Emotion Recognition (Article 5(1)(f) AI Act)This prohibition concerns AI systems that aim to infer the emotions (interpreted in a broad sense) of natural persons based on their biometric data and in the context of the workplace or educational and training institutions, except for medical or security reasons. Emotion recognition systems that do not fall under this prohibition are considered high-risk systems and deployers will have to inform the natural persons exposed thereto of the operation of the system as required by article 50(3) of the AI Act.
The European Commission refers here to certain clarifications contained in the AI Act regarding the scope of the concept of emotion or intention, which does not include, for example, physical states such as pain or fatigue, nor readily apparent expressions, gestures or movements unless they are used to identify or infer emotions or intentions. Therefore, a number of AI systems used for safety reasons would already not fall under this prohibition.
Similarly, the notions of workplace, educational and training establishments must be interpreted broadly. There is also room for member states to introduce regulations that are more favorable to workers with regard to the use of AI systems by employers.
It also clarifies that authorized therapeutic uses include the use of CE marked medical devices and that the notion of safety is limited to the protection of life and health and not to other interests such as property.
Biometric Categorization for certain “Sensitive” Characteristics (Article 5(1)(g) AI Act)This prohibition is for biometric categorization (except where purely ancillary to another commercial service and strictly necessary for objective technical reasons) that individually categorize natural persons on the basis of their biometric data to deduce or infer their race, political opinions, trade union membership, religious or philosophical beliefs, sex life or sexual orientation.
The European Commission clarifies that this prohibition, however, does not cover the labelling or filtering of lawfully acquired biometric datasets (such as images), including for law enforcement purposes (for instance, to guarantee that data equally represents all demographic groups).
Real-time Remote Biometric Identification (RBI) Systems for Law Enforcement Purposes (Article 5(1)(h) AI Act)The European Commission devotes a substantial part of the CGPAIP to the development of this prohibited practice, which refers to the use of real-time RBI systems in publicly accessible areas for law enforcement purposes. Exceptions, based on the public interest, are to be determined by the member states, through local legislation.
The CGPAIP concludes with a final section on safeguards and conditions for the application of the exemptions to the prohibited practices, including the conduct of Fundamental Rights Impact Assessments (FRIAs), which are defined as assessments aimed at identifying the impact that certain high-risk AI systems, including RBI systems, may have on fundamental rights, and which, it is clarified, do not replace the existing Data Protection Impact Assessment (DPIA) that data controllers (i.e., those responsible for processing personal data) must conduct and have a broader scope (covering not only the fundamental right to data protection but also all other fundamental rights of individuals) and which complement, inter alia, the required DPIA, the registration of the system or the need for prior authorization.
EDPB Adopts Opinion on UK Adequacy Decision Extension
On March 5, 2025, the European Data Protection Board (the “EDPB”) published Opinion 06/2025 on the extension of the European Commission Implementing Decisions under the GDPR and the Law Enforcement Directive on the adequate protection of personal data in the United Kingdom (the “Opinion”).
The Opinion was requested by the European Commission as the two current adequacy decisions are due to expire on June 27, 2025. For more background on the adequacy decisions, see our previous blog post here.
The extension of the adequacy decisions for a further six months gives the UK government time to enact the draft Data (Use and Access) Bill (the “DUA Bill”) which proposes several amendments to UK data protection law. The DUA Bill is currently in the House of Commons and likely to be finalised in the coming months. For further information on the changes to UK data legislation proposed by the DUA Bill, see here.
The EDPB clarified that the Opinion does not assess the UK data protection framework. Both the European Commission and the EDPB have stated their intentions to re-assess the UK legal framework following finalization of the proposed legislative changes in the UK, namely, the amends that shall be introduced upon the DUA Bill becoming enacted.
CNIPA Announces Deepening of “Blue Sky” Campaign to Strengthen Supervision of Intellectual Property Law Firms
On May 7, 2025, China’s National Intellectual Property Administration (CNIPA) released the Notice of the State Intellectual Property Office on deepening the “Blue Sky” campaign to strengthen the comprehensive governance of the intellectual property agency industry (国家知识产权局关于深入开展“蓝天”行动 强化知识产权代理行业综合治理的通知). The Blue Sky Campaign is somewhat similar to but more comprehensive than the USPTO’s recent launch of the Patent Fraud Detection and Mitigation Working Group. The Notice states that CNIPA will regulate agency behavior by 1. rectifying the behavior of patent agents that file “abnormal” patent applications including potential referral for criminal prosecution; 2. cracking down on unqualified patent agents; 3. crack down on illegal or irregular behavior of trademark agents; 4. strictly regulate solicitations; 5. rectify IP firms that do not complete licensing requirements; and 6. stop patent agents from renting their patent bar registrations. Further, CNIPA will aim to improve patent agent quality, improve the supervision of the IP firm industry, and increase IP publicity and education.
A translation follows. The original text is available here (Chinese only).
To the Intellectual Property Offices of all provinces, autonomous regions, municipalities directly under the Central Government and the Xinjiang Production and Construction Corps, and all relevant local centers; all departments of the National Intellectual Property Office, all departments of the Patent Office, the Trademark Office, other directly affiliated units of the Office, and all social organizations:
2025 is the final year for the implementation of the “14th Five-Year Plan for National Intellectual Property Protection and Utilization” and the year for the three-year special action on patent transformation and utilization. In order to strengthen the comprehensive governance of the intellectual property agency industry, improve the supervision system, improve the quality of agencies, and strongly support the work of patent transformation and utilization and intellectual property protection, the National Intellectual Property Administration has decided to continue the “Blue Sky” special rectification action in the intellectual property agency industry in 2025. The relevant matters are hereby notified as follows.
1. Regulate agency behavior and maintain industry order
(I) Concentrate on rectifying the behavior of acting as an agent for abnormal patent applications. A number of cases of acting as an agent for abnormal patent applications will be investigated and dealt with in a concentrated manner to form a high-pressure situation for centralized rectification. Intellectual property management departments in various places should adopt comprehensive measures and implement classified rectification by using various measures such as key inspections, warning talks, talks for rectification, warnings and fines, credit deductions, and self-discipline punishments according to the circumstances; if the circumstances are particularly serious, they should be reported to the National Intellectual Property Administration for handling in a timely manner. It is necessary to strengthen the connection between law enforcement and execution, and those suspected of crimes should be transferred to relevant departments in a timely manner for criminal prosecution. It is necessary to strictly implement the “double supervision” of institutions and personnel.
(II) Severe crackdowns on unqualified patent agents. Those who have a large amount of illegal income, act as agents for abnormal patent applications, deliberately transfer or destroy evidence, or refuse to cooperate with the investigation shall be fined a high multiple or the maximum amount in accordance with the law. At the same time, patent agencies that rent or lend their qualifications shall also be punished.
(III) Severely crack down on illegal and irregular behaviors of trademark agents. Intellectual property management departments in all regions should work with relevant departments to increase the coordination of supervision and law enforcement, and focus on cracking down on behaviors such as malicious preemptive registration of trademarks, hoarding of trademarks, application for registration of trademarks with major adverse effects, and malicious “three withdrawals” [cancellation requests of trademarks for non-use after three consecutive years].
(IV) Strictly regulate the solicitation of patent and trademark agency business. Intellectual property management departments in all regions should increase the intensity of Internet information monitoring, continue to monitor agency business solicitation information and collect evidence of illegal and irregular behaviors. For irregular solicitation of agency business, relevant institutions should be promptly ordered to make rectification within a time limit; for search engines, e-commerce platforms, forums and other Internet platform companies that publish agency business solicitation information, they should be urged to improve their internal screening management system, actively regulate the display content, and promptly shut down illegal agency shops and delete illegal information links.
(V) Strengthen rectification efforts for institutions that do not meet the licensing and filing conditions. Local intellectual property management departments should strengthen daily supervision and filing management of patent agencies and their branches. For patent agencies that do not meet the licensing conditions for a long time, urge them to promptly and properly handle the unfinished business and submit it to the National Intellectual Property Administration for handling.
(VI) Organize a cleanup of patent agents’ “hanging certificates” behavior [renting out patent bar registration numbers]. Organize a comprehensive investigation of patent agents suspected of “hanging certificates”. If patent agencies arbitrarily sign in the name of “hanging certificate” personnel to handle abnormal patent applications, local intellectual property management departments must severely handle them in accordance with laws and regulations.
2. Supply and demand are mutually driven to improve agent quality
(I) Strengthen policy guidance. Local intellectual property management departments should guide relevant units to adjust and improve internal management systems and relevant incentive policies in conjunction with special actions on patent transformation and utilization, and effectively avoid new abnormal patent applications.
(II) Standardize bidding behavior. Local intellectual property management departments should work with government procurement authorities to vigorously promote the “Patent and Trademark Agency Service Government Procurement Demand Standards (Trial)” and the model text of agency engagement contracts, carry out extensive and in-depth publicity activities, and promote state-owned enterprises, institutions, intellectual property power building demonstration units, listed companies, large private enterprises and other innovative entities to refer to and use them, and effectively improve the level of agency procurement and management. It is necessary to guide innovative entities to establish and improve a hierarchical and classified management mechanism for intellectual property agency services, and promote the realization of “high quality and high price” for agency services.
(III) Improve service capabilities. Intellectual property management departments in various regions should supervise and guide patent agencies to improve their internal management systems, improve service quality control mechanisms, implement the patent agent signature responsibility system, and improve their business capabilities such as patent writing, search and analysis, and technical understanding. Guide agencies to strengthen the compliance application of new technologies and improve their professional, digital, and intelligent levels. Encourage patent agencies to establish a service concept oriented towards promoting the industrialization of patents, expand service areas, innovate service models, and provide integrated patent transformation and application solutions. Relying on intellectual property service industry clusters, intellectual property service export bases, etc., we will increase the cultivation of foreign-related intellectual property service agencies, encourage them to conduct business abroad through the establishment of branches and joint operations, and provide high-quality and efficient intellectual property services for overseas enterprises.
III. Improve the working mechanism and strengthen the supervision system
(I) Deepen credit supervision. Intellectual property management departments in various regions should strictly implement the regulations on patent agency credit evaluation management, ensure that credit information is “fully returned” and credit evaluation is “fully evaluated”; strengthen the use of credit evaluation results, refine and improve the local incentives for credit keeping and restrictions on credit breaking, and promote the realization of “one place of credit breaking, restrictions everywhere”. Pilot areas for trademark agency credit evaluation management should organize pilot work in a solid manner, strengthen training and guidance for municipal and county intellectual property management departments, increase publicity and public disclosure of credit results information, and ensure that the pilot work achieves practical results.
(II) Strengthen coordinated supervision. Intellectual property management departments in various regions should further improve the cross-departmental coordination mechanism, and work with relevant departments to carry out joint inspections and joint law enforcement of intellectual property agencies. Continue to improve the cross-regional coordinated supervision mechanism, strengthen information exchange, experience sharing, supervision interaction, and mutual recognition of evaluation, and smooth the working mechanisms such as cross-provincial cooperation, law enforcement assistance, and case transfer. Encourage and support cross-regional exchanges and cooperation in intellectual property agency supervision, and continue to consolidate the national “one chessboard” working situation [Xi Jinping Thought: centralized, coordinated, and strategic governance, emphasizing a holistic view where all parts work together towards a unified national goal]. Strengthen cooperation and coordination with the Intellectual Property Protection Center, promptly inform the Intellectual Property Protection Center of information such as penalties and breach of trust of agencies, and promptly collect clues of illegal and irregular agency behaviors found in patent pre-examination business and deal with them in a coordinated manner.
(III) Innovate supervision methods. Intellectual property management departments in various regions should strengthen smart supervision, make full use of new technologies and tools such as artificial intelligence, collect various information on agencies and practitioners, build a multi-dimensional evaluation system, establish and improve the quality monitoring mechanism of agencies, and promote the transformation of the supervision model from “passive response” to “active prevention” based on “catching problems early and catching small problems”. We should continue to strengthen the publicity of information on agencies and practitioners, facilitate the public to inquire and compare, and promote the realization of the survival of the fittest in the market. We encourage the exploration of the filing of patent agency engagement contracts and other work, actively adopt non-site supervision methods such as remote inspection, and promote the realization of “ubiquitous and non-intrusive” supervision.
(IV) Enhance supervision capabilities. Local intellectual property management departments should organize rotation training for front-line agency supervision case handlers, accelerate the establishment of a database of key case handlers and consulting experts, and consolidate the talent base and professional support for agency supervision and law enforcement. Localities are encouraged to actively promote patent agency entrusted supervision, entrust the supervision functions of provincial patent agencies to the municipal level(districts under the jurisdiction of municipalities directly under the central government), and strengthen grassroots supervision. Localities are encouraged to establish and improve the intellectual property agency supervision regulations and systems, and formulate and issue the administrative penalty discretion benchmarks for intellectual property agencies in their regions in accordance with the law.
IV. Strengthen publicity and education to create a favorable atmosphere
(I) Increase publicity and guidance efforts. Intellectual property management departments in various regions should adhere to the principle of giving equal importance to supervision and law enforcement and publicity and education, and combine various activities such as the “National Intellectual Property Publicity Week”, “Intellectual Property Service Tour”, and “China Brand Day” to strengthen the publicity and implementation of laws and regulations related to intellectual property agency, tell good “industry stories”, and actively publicize the important role of the intellectual property agency industry in serving technological innovation and trademark brand building, promoting the development of new quality productivity, and promoting high-level opening up, so as to enhance the positive image of the industry. Encourage local governments to organize intellectual property agency professional skills competitions, intellectual property agency campus special recruitment and other activities according to local conditions to increase the attractiveness of the agency industry to high-quality talents. Encourage local governments to innovate publicity methods, expand publicity channels, release publicity films for the intellectual property agency industry and short videos of special rectification actions, create a good public opinion atmosphere for combating illegal agency behaviors, and guide the public to improve their identification ability and actively choose high-quality agency services.
(II) Create a good industry atmosphere. Intellectual property management departments in various regions should increase the exposure of warning cases of intellectual property agency, explain the law through cases, popularize the law through cases, and guide agencies to operate in accordance with the law and in good faith. Together with industry organizations, they should carry out self-discipline initiatives and industry style building activities for standardized operations, vigorously promote the list of prohibited practices for patent and trademark agency, and guide agencies to consciously accept social supervision. Organize and carry out professional ethics and professional discipline education for patent agents and trademark agents, strengthen education and training for newly established agencies and first-time practicing patent agents, and continuously enhance practitioners’ sense of responsibility and sense of professional honor.
The National Intellectual Property Administration will continue to strengthen supervision and guidance on the agency supervision work of local intellectual property management departments, organize exchanges and discussions, cross-regional joint supervision and other promotion activities, and regularly report progress and useful experiences.
Cyberspace Administration of China Cracks Down on Improper Use of Minors’ Images
Since the beginning of 2025, the Cyberspace Administration Authority (“Authority”) has continued to strengthen the protection of minors on the Internet and clean up illegal and undesirable information that uses the images of minors, as well as removing non-compliant accounts.
The Authority has requested that platform operators increase their efforts to identify and combat signs of violations and rigorously examine the content of information involving minors posted on their platform. The Authority has taken measures that include banning accounts and canceling profit-making privileges for accounts, shutting down more than 11,000 accounts on the basis of legal violations.
Regulation Round Up: April 2025
Welcome to the UK Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation.
Key Developments in April 2025:
29 April
ESG: The FCA updated its webpage on its consultation paper on extending the sustainability disclosure requirements (“SDR”) and investment labelling regime to portfolio managers (CP24/8). In the light of feedback received, it has decided that it is not the right time to finalise rules on extending the regime to portfolio managers.
Cryptoassets: The European Securities and Markets Authority (“ESMA”) published its final report on guidelines relating to supervisory practices for national competent authorities to prevent and detect market abuse under Article 92(2) of the Regulation on markets in cryptoassets ((EU) 2023/1114).
24 April
Regulatory Capital: The FCA has published a consultation paper on the definition of capital for investment firms (CP25/10). CP25/10 outlines the FCA’s proposals to simplify and consolidate the rules as they relate regulatory capital.
17 April
Listing Regime: The FCA has published Primary Market Bulletin No 55 which addresses proposed changes to the listing regime.
16 April
ESG: The Omnibus I Directive (EU) 2025/794 amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards the dates from which member states are to apply certain corporate sustainability reporting and due diligence requirements was published in the Official Journal of the European Union. Please refer to our dedicated article on this topic here.
15 April
AIFMD 2.0: ESMA has published final reports setting out the final guidelines and draft technical standards on liquidity management tools under the Directive amending the Alternative Investment Fund Managers Directive (2011/61/EU) (“AIFMD”) and the UCITS Directive (2009/65/EC) ((EU) 2024/927) (“AIFMD 2.0”). Please refer to our dedicated article on this topic here.
14 April
Regulatory Initiatives Grid: The Forum members (the Bank of England, the Prudential Regulatory Authority, the FCA, the Payment Systems Regulator, the Competition and Markets Authority, the Information Commissioner’s Office, the Pensions Regulator, and the Financial Reporting Council) published a joint regulatory initiatives grid relevant to the financial services sector.
11 April
FCA Regulatory Perimeter: HM Treasury has published a policy paper containing a record of the meeting between the Economic Secretary to the Treasury and the Chief Executive of the FCA. The purpose of the meeting was to discuss the FCA’s perimeter and the issues set out in its December 2024 report.
Trading Platforms: The FCA has published a webpage summarising the findings from its multi-firm review of trading apps (also more commonly known as “neo-brokers”).
10 April
ESG: ESMA has published a risk analysis report on the increased incorporation of ESG terms into fund names and its impact on investment flows.
MiFID II: ESMA has published a final report on regulatory technical standards supplementing the Markets in Financial Instruments (“MiFID II”) Directive (2014/65/EU) to specify the criteria for establishing and assessing the effectiveness of investment firms’ order execution policies.
9 April
Artificial Intelligence: The Financial Policy Committee published a report on artificial intelligence in the financial system.
ESG: ESMA has published a final report setting out its analysis and conclusions on a common supervisory action exercise conducted with the national competent authorities on ESG disclosures under the Benchmarks Regulation ((EU) 2016/1011).
8 April
MiFID II: ESMA has published a final report containing technical advice to the European Commission on amendments to the research provisions in the MiFID II Directive in the context of changes introduced by the Listing Act (ESMA35-335435667-6290).
FCA Strategy: The FCA has published it annual work programme for 2025/26, which sets out how it will deliver its four strategic priorities (to be a smarter regulator that is more efficient and effective, supporting growth, helping consumers navigate their financial lives and fighting financial crime).
7 April
UK AIFMD: The FCA has published a call for input and HM Treasury has published a consultation on the future regulation of alternative investment fund managers. Please refer to our dedicated article on this topic here.
3 April
ESG: The European Parliament plenary session formally adopted at first reading the stop-the-clock proposal for a Directive amending Directives (EU) 2022/2464 and (EU) 2024/1860 with respect to the dates from which member states are expected to align to corporate sustainability reporting and due diligence requirements.
ESG: The FCA has published a summary of the feedback it has received in relation to its discussion paper on finance for positive sustainable change (DP23/1) together with its response and next steps. Please refer to our dedicated article on this topic here.
1 April
Short Selling: The FCA published an updated version of its webpage on the notification and disclosure of net short positions.
Motor Finance: The FCA has published its written submissions to the Supreme Court in the appeal of the Court of Appeal decision in Johnson v FirstRand Bank Ltd (London Branch) t/a Motonovo Finance [2024] EWCA Civ 1282.
ESG: The EU Platform on Sustainable Finance has published a report on its first review of the Taxonomy Climate Delegated Act and the development of technical screening criteria for a list of new economic activities.
Additional Authors: Sulaiman Malik and Michael Singh
Canada Implements Temporary Employment Insurance Measures Responsive to Economic Impacts of Trade War
Quick Hits
The Canadian government has amended the Employment Insurance Act to temporarily suspend certain repayment rules for severance payments due to job separations occurring between March 30, 2025, and October 11, 2025.
Employees who receive both severance pay and employment insurance benefits during the specified period will not have to repay their employment insurance benefits.
Repayment obligations for employment insurance can still apply to terminations before March 30, 2025, even if severance payments are made after that date.
Of particular interest to employers and employees, the temporary measures suspend certain rules relating to monies paid because of a temporary or permanent separation from employment. These temporary rules will apply to any monies paid as a result of a separation of employment that occurs between March 30, 2025, and October 11, 2025.
The temporary measures outline that severance payments made because of a separation between these dates will no longer trigger repayment obligations where an individual receives both severance pay and employment insurance benefits. Previously, an employee who had received employment insurance payments and later received severance payments would have a repayment obligation. A similar suspension of repayment obligations was implemented in response to the deleterious effects of COVID-19.
Employment insurance repayment obligations can still apply to any termination of employment that occurred before March 30, 2025, even if payments are made after that date.
These changes will certainly be relevant in assessing severance packages and termination settlements, but for the time period outlined above, it appears that employees will be able to keep both employment insurance benefits and termination pay.
UK’s Collective Licensing Initiative Aims to Harmonize AI and Copyright Law
In a significant move to address the tension between copyright and generative artificial intelligence (AI), the UK’s Copyright Licensing Agency (CLA), Authors’ Licensing and Collecting Society (ALCS), and Publishers’ Licensing Services (PLS) have announced plans to launch a collective licensing framework for AI training. The opt-in license would allow AI developers to use text-based published works—such as books, journals, and magazines—for training, fine-tuning, and retrieval-augmented generation (RAG) while ensuring that creators are compensated. The license is expected to roll out in Q3 2025, following further consultation with publishers.
The UK government’s consultation “Copyright and Artificial Intelligence” acknowledged that current UK copyright law leaves both rights holders and AI developers navigating uncertainty. It proposed two main solutions: (1) strengthened rights reservation mechanisms and (2) a fallback copyright exception for AI training where rights were not reserved. However, rights holders strongly opposed a “catch-all” exception, arguing it would erode transparency and remuneration. Their opposition helped catalyze the development of this licensing framework as a market-based alternative.
The framework is being built collaboratively by CLA, ALCS (representing authors), and PLS (representing publishers). CLA—already the UK’s recognized collective management organization for text content—would administer the license, collecting and distributing fees to right holders after operational costs. It would cover a broad range of text-based published works under CLA’s mandate, streamlining permissions for AI developers where individual negotiations would be impractical. Rights holders would affirmatively opt in by registering works, while unregistered works would remain outside the license’s scope. This would apparently avoid the “opt-out” burden creators criticized in the government’s exception proposal, instead requiring affirmative consent to participate.
Importantly, the proposed collective license is intended to complement, not replace, direct bespoke licensing deals between large publishers or rights holders and AI firms. It provides an accessible fallback particularly for smaller creators and independent publishers who may otherwise struggle to negotiate individually.
An initial phase of publisher consultation has already concluded, with a second round scheduled for later in 2025. The framework’s rollout will follow the launch of related TDM and workplace-use licenses slated to commence on May 1, 2025. Exact compensation models are still under negotiation but will aim to balance affordability for AI developers against fair, sustainable remuneration for creators. License fees collected will be allocated among ALCS and PLS members based on established distribution rules.
The framework is accompanied by the development of a national rights reservation registry, intended to facilitate machine-readable licensing metadata and help signal licensing preferences at scale. Licensees would also be subject to robust transparency requirements, including reporting on the works used, methods of content acquisition, and downstream uses, with the ultimate goal of reinforcing trust between the creative industries and AI developers.
Although UK-focused, the licensing framework is being designed with international interoperability in mind, offering access to licensed content to AI developers worldwide, including US-based firms. If successful, it could serve as a model for future cross-border AI licensing solutions.
The UK’s proposed collective licensing framework represents a pragmatic approach to reconciling the needs of AI innovation with the requirements of copyright law. While the implementation process is likely to raise novel challenges, the initiative is designed to provide voluntary, transparent, and scalable alternative to statutory exceptions in the UK; protecting the economic interests of creators while enabling responsible AI development. If successful, it may offer valuable insights for other jurisdictions seeking to balance technological advancement with the protection of creative rights.
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