What “copyright duration” means
Copyright duration (also called copyright term) is the statutory period during which exclusive rights in a work are protected by copyright law. After the term expires, the work permanently enters the public domain in that jurisdiction—free for lawful reproduction, adaptation, and commercial use without licensing fees or permissions.
Duration is usually measured from the death of the author for personal works (post-mortem auctoris), or from publication/creation for corporate categories (work made for hire, anonymous titles, audiovisual productions). Platform takedowns and DMCA counter-notices do not alter statutory duration clocks.
Berne Convention minimum standards
Most nations belong to the Berne Convention for the Protection of Literary and Artistic Works (Article 7), which requires national treatment and sets a minimum baseline of the author's life plus 50 years (Life + 50) for general literary and artistic works. Member states are legally permitted to grant longer protection terms, but cannot fall below this treaty floor.
Over the past three decades, major economic blocs have expanded statutory terms to Life + 70 years (such as the EU Term Directive 2006/116/EC and the US Sonny Bono Copyright Term Extension Act).
Key Jurisdiction Statutory Snapshots (BLUF)
Direct statutory answers for primary search markets—optimized for rapid rights clearance and quick legal reference:
United States
Duration: Life + 70 years for personal authors (post-1977 works). Corporate works made for hire last 95 years from publication or 120 years from creation (17 U.S.C. § 302).
View US statutory notes ↓European Union
Duration: Life + 70 years harmonized across member states (Directive 2006/116/EC). The Rule of the Shorter Term applies strictly to non-EU works under Berne Article 7(8).
View EU statutory notes ↓United Kingdom
Duration: Life + 70 years for literary, dramatic, musical, and artistic works (CDPA 1988). Sound recordings and broadcasts are protected for 70 years from lawful release.
View UK statutory notes ↓Vietnam
Duration: Life + 50 years for personal authors (IP Law Article 27). Cinematographic, photographic, applied art, and corporate works last 75 years from publication.
View Vietnam statutory notes ↓Top 10 Global Jurisdictions at a Glance (2026 Reference)
| Jurisdiction | Individual Author Term | Corporate / Work Made for Hire | Public Domain Cutoff (2026) | Governing Statute |
|---|---|---|---|---|
| 🇺🇸 United States | Life + 70 Years | 95 years from pub / 120 from creation | Works published in 1930 or earlier (in 2026) | 17 U.S.C. § 302 |
| 🇪🇺 European Union | Life + 70 Years | 70 years from lawful publication | Authors deceased in 1955 or earlier (in 2026) | Directive 2006/116/EC |
| 🇬🇧 United Kingdom | Life + 70 Years | 70 years (Crown: 50–125 years) | Authors deceased in 1955 or earlier (in 2026) | CDPA 1988 |
| 🇯🇵 Japan | Life + 70 Years (extended 2018) | 70 years from publication | Authors deceased in 1955 or earlier (in 2026) | Copyright Act Art. 51–54 |
| 🇨🇦 Canada | Life + 70 Years (extended 2022) | 75 years from publication | Authors deceased in 1971 or earlier (in 2026) | Copyright Act s. 6 |
| 🇦🇺 Australia | Life + 70 Years (extended 2004) | 70 years from publication | Authors deceased in 1955 or earlier (in 2026) | Copyright Act 1968 s. 33 |
| 🇨🇳 China | Life + 50 Years | 50 years from publication | Authors deceased in 1975 or earlier (in 2026) | PRC Copyright Law Art. 23 |
| 🇻🇳 Vietnam | Life + 50 Years | 75 years from publication (Film/Photo/Corp) | Authors deceased in 1975 or earlier (in 2026) | Luật SHTT Điều 27 |
| 🇸🇬 Singapore | Life + 70 Years | 70 years from publication | Authors deceased in 1955 or earlier (in 2026) | Copyright Act 2021 |
| 🇲🇽 Mexico | Life + 100 Years (World Record) | 100 years from publication | Authors deceased in 1925 or earlier (in 2026) | LFDA Art. 29 |
The “Rule of the Shorter Term” & The Cross-Border Copyright Trap
When a work created in one country is exploited or hosted in another, international copyright law applies Article 7(8) of the Berne Convention, known as the Rule of the Shorter Term (or Comparison of Terms):
Berne Convention Article 7(8) Principle
"In any case, the term shall be governed by the legislation of the country where protection is claimed; however, unless the legislation of that country otherwise provides, the term shall not exceed the term fixed in the country of origin of the work."
The Cross-Border Trap: While the European Union strictly enforces the Rule of the Shorter Term for non-EU works, the United States does not apply it across the board. Under the Uruguay Round Agreements Act (URAA, 17 U.S.C. § 104A) and affirmed by the US Supreme Court in Golan v. Holder (2012), the US restored federal copyright protection in millions of foreign works that had already entered the public domain in their home countries.
This asymmetry is heavily exploited in copyfraud attacks: bad-faith competitors file false DMCA notices against US-hosted websites using public domain imagery or text, falsely claiming active international protection. Identifying the exact country of origin and applicable rule is essential to appeal wrongful takedowns.
The T.E.R.M.S™ Multi-Jurisdiction Clearance Matrix
To verify whether a work is legally in the public domain and safe from cross-border copyright infringement claims, compliance officers and publishers use the T.E.R.M.S™ Clearance Protocol:
- T — Treaty Baseline: Verify if the origin country is an active signatory to the Berne Convention, WIPO Copyright Treaty (WCT), or TRIPS Agreement.
- E — Entity Type & Author Class: Determine whether the work is individual authorship (Life + 50/70/100) or a corporate work made for hire (fixed 70–95 years from first publication).
- R — Rule of the Shorter Term Check: Assess whether the host country applies term comparison (EU model) or domestic statutory terms regardless of origin (US URAA § 104A model).
- M — Medium-Specific Clocks: Audit separate statutory clocks for sound recordings (Music Modernization Act), motion pictures, and photographs which often differ from literary works.
- S — Safe Harbor & Public Domain Defense: Preserve verified timestamped records of author death dates or first publication dates to immediately defeat bad-faith DMCA takedowns via statutory counter-notices.
Interactive Global Public Domain & Expiration Calculator
Use this calculator to determine when a creative work enters the Public Domain under major international copyright frameworks (accounting for the standard January 1st post-expiry rule):
Calculate Copyright Expiration Date
How to read the table
- General term describes typical author-owned literary/artistic works—not every category.
- Notes flag work-made-for-hire, anonymous works, films, sound recordings, or enforcement caveats.
- Instrument + primary link point to the statute family and a live starting URL—always open the official text before citing.
- Confidence tells editors how hard we verified the row (high / medium / low). Prefer high-confidence rows for outreach citation.
Methodology & confidence labels
- General term column = typical author-owned literary/artistic works, not every category.
- Films, photos, sound recordings, anonymous works, and government works often use different clocks.
- Confidence high = cross-checked against official FAQ / code / well-documented statute summaries.
- Confidence medium = statute name + reputable secondary (WIPO/UNESCO/IPO summaries); re-verify before citation.
- Confidence low = limited open English sources or atypical enforcement; do not treat as primary authority.
- DMCA / platform takedowns never rewrite statutory duration.
QA note (2026-07-12): Anguilla and Bermuda corrected to life + 50 (not UK-style life + 70). Jamaica life + 95 retained with reform notes. Vietnam category exceptions (e.g. audiovisual/photo) called out explicitly. Vietnam primary link points to the Vietnamese Government consolidated IP Law (vanban.chinhphu.vn), not a foreign mirror.
Copyright term by country (reference table)
Simplified educational summary. Outreach-priority markets are listed first. Verify primary law before rights clearance.
| Country / jurisdiction | Confidence | Typical general term | Notes & primary source |
|---|---|---|---|
| United States · core | high | Life + 70 years (works created on/after 1 Jan 1978) | Works made for hire / anonymous / pseudonymous: generally 95 years from publication or 120 from creation, whichever is shorter. Pre-1978 published works follow a different regime (often up to 95 years from publication if renewed). Registration is not required for protection to exist but affects US remedies. 17 U.S.C. §§ 302–304; Copyright Office Circular 15A · Primary / official start |
| Vietnam · core | high | Life + 50 years (most author works under IP Law) | Cinematographic, photographic, applied-art and certain anonymous works commonly use fixed terms from first publication (often 75 years under current IP Law framing)—not life+50. Moral rights rules and related rights differ. Primary source is the Vietnamese consolidated IP Law on the Government portal (Văn bản hợp nhất Luật SHTT); also see IP Viet Nam (ipvietnam.gov.vn) for guidance pages. Luật Sở hữu trí tuệ (Điều 27) — VB hợp nhất 155/VBHN-VPQH (VPQH); Luật 50/2005/QH11 & sửa đổi · Primary / official start |
| European Union (general) · core | high | Life + 70 years (Term Directive baseline for author works) | Member states implement EU term rules in national statutes. Neighboring rights and related categories follow separate terms. Always cite the national act for clearance. Directive 2006/116/EC (as amended) + national implementations · Primary / official start |
| United Kingdom · core | high | Life + 70 years (CDPA framework for most literary works) | Post-Brexit, EU directives no longer auto-update UK term. Category rules (sound recordings, broadcasts, Crown copyright) differ—see IPO guidance. Copyright, Designs and Patents Act 1988; IPO UK guidance · Primary / official start |
| Canada · core | high | Life + 70 years (after Bill C-19 term extension) | Extension to life+70 generally applies from 30 Dec 2022. Works that were already public domain before the change typically stay public domain (non-retroactive extension). Confirm CIPO materials for edge cases. Copyright Act (Canada); Bill C-19 / BIA 2022 amendments · Primary / official start |
| Australia · core | high | Life + 70 years (general literary/artistic works) | Different rules may apply to government works, films, and sound recordings. Australian Copyright Council fact sheets are useful secondary summaries. Copyright Act 1968 (Cth) · Primary / official start |
| Japan · core | high | Life + 70 years (after term extension) | Cinematographic works and neighboring rights use separate category rules. Confirm Agency for Cultural Affairs / statute text for clearance. Copyright Act of Japan · Primary / official start |
| Singapore · core | high | Life + 70 years (modern Copyright Act framework) | Posthumous works, photographs, sound recordings, and broadcasts can use publication/making-based terms. IPOS factsheets summarize basics. Copyright Act 2021 (Singapore); IPOS guidance · Primary / official start |
| China · core | high | Life + 50 years (general works of natural persons) | Films, photographic works, and works of legal entities often use 50-year terms counted from publication/completion rather than life+50. Software and neighboring rights need separate checks. Copyright Law of the PRC (amended) · Primary / official start |
| India · core | high | Life + 60 years (literary/dramatic/musical/artistic) | Photographs, films, and sound recordings generally use 60 years from publication (not life+60). Confirm Copyright Act 1957 as amended. Copyright Act, 1957 (as amended) · Primary / official start |
| Germany · core | high | Life + 70 years | Urheberrechtsgesetz (UrhG). Neighboring rights (Leistungsschutzrechte) use different terms. UrhG; gesetze-im-internet.de · Primary / official start |
| France · core | high | Life + 70 years | Strong moral rights tradition. Code de la propriété intellectuelle governs economic rights term. Code de la propriété intellectuelle (CPI) · Primary / official start |
| Brazil · core | high | Life + 70 years | Moral rights and neighboring rights have additional details under Law 9.610/1998. Lei de Direitos Autorais (Law 9.610/1998) · Primary / official start |
| South Korea · core | high | Life + 70 years | Category-specific rules for neighboring rights; confirm consolidated Copyright Act text. Copyright Act of Korea · Primary / official start |
| Netherlands · core | high | Life + 70 years | Auteurswet; EU-aligned term for author works. Neighboring rights separate. Dutch Copyright Act (Auteurswet) · Primary / official start |
| Afghanistan | medium | Life + 50 years | Confirm current Official Gazette / MoJ text; transitional instruments may affect practice. National copyright statute (life+50 framing in open digests) · Primary / official start |
| Andorra | medium | Life + 70 years | Collective/unknown authorship may use 70 years from publication/creation. Small jurisdiction—check official consolidated text. Andorran copyright legislation (Art. 18 lineage) · Primary / official start |
| Anguilla | medium | Life + 50 years | Overseas territory. Open secondary lists (including Wikimedia duration tables) report life + 50—not UK life + 70. Confirm local IP guidance before reliance. Anguilla copyright rules (territory IP guidance) · Primary / official start |
| Antigua and Barbuda | medium | Life + 50 years | Anonymous, computer-generated, sound recording and film works often use 50 years from publication/creation under Copyright Act 2002 summaries. Copyright Act 2002, s.10 lineage · Primary / official start |
| Bangladesh | medium | Life + 60 years (literary/musical/artistic under Copyright Act) | Cinematographic films, sound recordings, photographs, and many government works often use 60 years from publication. Confirm Copyright Act 2000 consolidations. Copyright Act 2000 (Bangladesh) · Primary / official start |
| Bermuda | medium | Life + 50 years | Secondary duration tables commonly list life + 50 (not life + 70). Confirm Bermuda Government IP fact sheets for category exceptions. Bermuda copyright legislation / government fact sheets · Primary / official start |
| Chile | medium | Life + 70 years | Term extended in the FTA era; verify consolidated IP code for category exceptions. Chilean IP / copyright legislation (post-FTA consolidations) · Primary / official start |
| Denmark | high | Life + 70 years (EU term alignment) | Consolidated Copyright Act; neighboring rights separate. Danish Copyright Act; Ministry of Culture consolidations · Primary / official start |
| Israel | medium | Life + 70 years (Copyright Act 2007 framework) | Confirm official Hebrew/English consolidated text for exceptions and related rights. Copyright Act, 2007 (Israel) · Primary / official start |
| Jamaica | medium | Life + 95 years (modern term for many author works) | 2015 reforms substantially lengthened terms (among the longest worldwide). Transitional rules can depend on death/publication dates. Verify current Copyright Act sections before clearance. Jamaica Copyright Act (as amended; s.10 lineage per secondary digests) · Primary / official start |
| Kenya | medium | Life + 50 years | Confirm latest consolidated Kenyan copyright statute and regulations; related rights may differ. Kenya Copyright Act (consolidated) · Primary / official start |
| Namibia | medium | Life + 50 years | Verify current Copyright Act and any TRIPS/FTA-driven updates against official text. Namibia copyright statute · Primary / official start |
| North Korea | low | Statutory terms reported in secondary analyses (treat as non-operational for commercial clearance) | Open English primary sources are scarce; practical enforcement is atypical. Do not use for rights clearance or BLB citation replacement. Secondary analyses of DPRK Copyright Act only · Primary / official start |
| Norway | high | Life + 70 years | Åndsverkloven framework; regulations supplement the Act. Norwegian Copyright Act; Lovdata · Primary / official start |
| Saudi Arabia | medium | Life + 50 years (author economic rights) | Legal-person / anonymous / audiovisual / applied-art works use publication- or completion-based terms under current Saudi copyright law summaries (including 2026 law commentary). Prefer Arabic statute + official English if available. Saudi copyright law (current consolidated / 2026 reform materials) · Primary / official start |
| Spain | high | Life + 70 years | Texto refundido de la Ley de Propiedad Intelectual lineage (e.g. RDL 1/1996 as amended). Spanish consolidated IP law · Primary / official start |
| Sri Lanka | medium | Life + 70 years | Audiovisual and unpublished works can use different publication/completion clocks—confirm NIPO guidance. Sri Lanka copyright legislation; NIPO materials · Primary / official start |
| Syria | low | Life + 50 years (Law No. 12/2001-era framing in open digests) | Conflict and enforcement conditions may affect practical access. Prefer primary Arabic text over historical English PDFs alone. Syrian copyright law texts (Law 12/2001 lineage) · Primary / official start |
| Uganda | medium | Life + 50 years | URSB guidance URLs change frequently—prefer statute text over brochure pages. Uganda Copyright and Neighbouring Rights Act lineage; URSB materials · Primary / official start |
| Vatican City | low | Special regime — do not assume EU defaults | Historical Italian-language instruments; rare commercial use case. Not suitable as a general citation substitute for EU term rules. Historical Vatican copyright instruments · Primary / official start |
Regional patterns
- Europe: Life + 70 is common for author works after EU term harmonization (national laws still matter).
- United States: Life + 70 for most post-1977 personal works; separate hire/anonymous rules.
- Many Berne members outside the EU/US: Life + 50 remains a frequent baseline, with extensions in some markets.
- Asia-Pacific: Mixed—Japan/Singapore often life + 70; China/Vietnam commonly life + 50 for many works.
Vietnam vs United States vs European Union (Comprehensive Comparison)
| Legal Factor | United States (17 U.S.C.) | European Union (Directives) | Vietnam (IP Law 2022) |
|---|---|---|---|
| Personal Author Works | Life + 70 years (post-1977 creations) | Life + 70 years (harmonized) | Life + 50 years (Article 27) |
| Work Made for Hire / Corporate | 95 years from publication or 120 from creation | 70 years from lawful publication | 75 years from publication (or 100 from fixation) |
| Sound Recordings | 70–95 years (Music Modernization Act) | 70 years from performance/fixation | 50 years from fixation date |
| Rule of the Shorter Term | Not applied broadly (URAA § 104A restores terms) | Mandatory for non-EU works (Art. 7) | Applied on reciprocal international basis |
| Protection Enforcement | DMCA § 512 Notice & Counter-Notice | Digital Services Act & National Courts | Decree 17/2023/ND-CP Intermediary Rules |
If a competitor files an invalid takedown against public domain content on your domain, statutory duration serves as definitive legal evidence. Learn how to identify copyfraud, understand penalties under 17 U.S.C. § 512(f), or file an expedited counter-notice.
Notable Public Domain Milestone: Steamboat Willie & The Trademark Trap
On January 1, 2024, the original 1928 animated short Steamboat Willie (introducing Mickey and Minnie Mouse) officially entered the US Public Domain after 95 years of copyright protection under the Sonny Bono Copyright Term Extension Act (17 U.S.C. § 304).
Copyright Expiration vs Trademark Rights: The Legal Border
While the original 1928 black-and-white audiovisual work can now be freely copied, screened, and adapted worldwide without copyright licenses, creators must navigate crucial legal distinctions:
- What is Free (Public Domain): The exact 1928 character design, whistle sequence, and animation frames from Steamboat Willie and Plane Crazy.
- What Remains Protected: Subsequent iterations of Mickey Mouse (e.g., Sorcerer Mickey, modern colorized versions, white gloves introduced later) remain under separate active copyright terms.
- The Perpetual Trademark Shield: The Walt Disney Company holds active trademarks on the Mickey Mouse character as a corporate brand identifier. Under the US Supreme Court ruling in Dastar Corp. v. Twentieth Century Fox Film Corp. (2003), trademark law cannot be used to extend expired copyright monopolies, but creators cannot mislead consumers into believing their derivative works are endorsed by Disney.
Enforcement Insight: Automated copyright detection bots frequently misidentify lawful public domain adaptations on Google and YouTube. Retaining timestamped evidence of publication year (1928) and expired statutory term calculations enables publishers to swiftly defeat abusive strikes via statutory DMCA counter-notices.
DMCA, Google Removal, and Statutory Duration
A successful or unsuccessful DMCA index check does not modify statutory copyright terms. Duration is set strictly by national copyright statutes. Search engine de-indexing affects search visibility, not the underlying term clock. If your lawful or public domain content was delisted, you have the statutory right to file a formal counter-notice to mandate Google restore your indexation within 10–14 business days.
FAQ
How long does copyright last in the United States?
For most works created on or after 1 January 1978, copyright lasts for the life of the author plus 70 years. Works made for hire and certain anonymous or pseudonymous works generally last 95 years from publication or 120 years from creation, whichever expires first. Pre-1978 works follow a different set of rules. See copyright.gov duration FAQ.
Is copyright duration the same in every country?
No. The Berne Convention sets minimum standards (commonly life of the author plus at least 50 years for many works), but countries may grant longer terms. Always check the national statute that governs the work and the country where protection is claimed.
What is the copyright term in Vietnam?
Under Vietnam’s Intellectual Property Law (Luật Sở hữu trí tuệ, see the consolidated text on vanban.chinhphu.vn), many author works are protected for the life of the author plus 50 years. Cinematographic, photographic, applied-art and some anonymous works often use fixed terms from first publication (commonly discussed as 75 years in current consolidations)—not life+50. Confirm the latest consolidated VBHN text and guiding decrees; IP Viet Nam (ipvietnam.gov.vn) publishes related guidance.
When does a work enter the public domain?
A work typically enters the public domain when its copyright term expires, or when the right holder dedicated it to the public domain, or when it was never eligible for copyright. Term expiry is country-specific; a work can be public domain in one country and still protected in another.
Does a DMCA takedown change copyright duration?
No. A DMCA notice or Google de-index action is a notice-and-takedown / intermediary process. It does not shorten or extend the underlying copyright term. Duration is set by copyright law, not by platform procedures.
How reliable is this table for citation?
Use high-confidence rows as a starting map, then open the primary URL / statute before citing in legal or editorial work. Medium- and low-confidence rows need independent verification. This page is educational, not a substitute for primary law.
Sources, update policy, and how to cite this page
We maintain this table for researchers, editors, and website owners who encounter dead official PDFs (including broken Wikipedia citations). Prefer primary statutes and official IP office pages when available. Historical UNESCO country files and treaty mirrors are useful for archaeology of sources—not as a substitute for current law.
How we cite: each row includes an instrument label and a starting primary URL. For editorial replacement of a broken link, open that URL (or WIPO Lex / national gazette) and quote the statute section—not only this summary cell.
Suggested citation: DMCA AI, “Copyright duration by country,” 2026-07-12,https://dmcaai.com/en/copyright-duration-by-country/
Related reading: What is copyright? · What is copyfraud? · Public domain · AI and copyright · How to report DMCA abuse · Avoid DMCA penalties · English blog