Artificial Intelligence — The Korea Music Copyright Association (KOMCA), South Korea's largest music copyright collective management organization, has revoked its previous regulations prohibiting the registration of artificial intelligence (AI)-assisted musical works. This amendment expands the scope of registerable works while simultaneously introducing stricter disclosure obligations and clearer enforcement measures.

KOMCA announced the revised registration standards in a notice published on August 4, 2026, with the amended rules taking effect immediately.

KOMCA: From the "Zero Percent" Rule to Conditional Acceptance of AI Works

KOMCA's new approach replaces its former "zero percent" policy, which had been in force since March 24, 2025. Under the old rule, creators were required to confirm that a work was created entirely by human effort without any involvement of artificial intelligence.

Under the revised system, AI-assisted works may be registered when human creators make a substantial and dominant creative contribution. According to the KOMCA copyright registration form updated on August 3, 2026, this means that human creative participation accounts for more than half of the creation process. However, KOMCA has drawn a clear line against works generated purely from prompts. In actual filings, applicants must confirm that the work was not directly generated solely by prompts.

Disclosure as a Mandatory Condition for Registration

Applicants must now explicitly list and confirm which parts of the work used AI, what AI tools were used, the specific manner in which each tool was utilized, and the creative contribution of the human creator in each relevant section (including lyrics, composition, and arrangement). Applications cannot simply state in general terms that "AI was used," but must elaborate in detail on the stages where AI intervened and the specific contributions made by the human creator.

In addition, when registering AI-assisted works, registrants must separately confirm all AI-related representations and warranties, including that the work remains a human work created based on substantial and dominant human creative choices and expressions.

Retention of Materials and Evidentiary Requirements: "Retaining Evidence Throughout the Entire Creative Process"

KOMCA ties work registration to verifiable evidence of human creation. The notice requires creators to retain materials that can reconstruct the creative process (such as Digital Audio Workstation (DAW) project files, revision history records, sheet music, and prompt logs) and save all relevant modification records. KOMCA has the right to request the aforementioned materials, and applicants must promptly submit supporting documents upon receiving a notice to produce them.

The notice also provides review procedures for registration cases under doubt. KOMCA may conduct technical verifications or initiate internal review procedures to verify AI usage, inspect the authenticity of declared disclosures, and determine whether the human contribution reaches the "substantial and dominant" standard.

Consequences of False Declarations: Major Financial and Contractual Risks

In accordance with the Association's articles of incorporation and contractual terms, the notice sets out the direct consequences corresponding to false declarations. Remedial measures include the withholding of royalties, clawback of improperly obtained funds, enforcement of contractual breach damages, and termination of copyright trust agreements. In other words, the disclosure and verification requirements are paired with a complete set of remedies for breach, which directly impacts a creator's cash flow and their ability to continue using KOMCA's comprehensive copyright management framework.

New Requirements for Filings by Agents and Collaborative Works

KOMCA has simultaneously tightened procedural rules under common application models. For registration applications submitted by an agent, a written power of attorney signed by the principal must now be submitted, which must explicitly encompass AI-related declarations, confirmations, representations, warranties, and undertakings; however, representations and warranties regarding the human making a substantial and dominant creative contribution and not utilizing prompt-only generation must be made in the name of the principal. For collaborative works, co-authors may submit and confirm their own contributions, and may report the contributions of other co-authors based on the information obtained. KOMCA sets a 7-day objection period following the completion of the registration notice.

Differences from the US System

On the surface, KOMCA's new rules closely resemble the guidelines of the US Copyright Office. The US allows the registration of AI-assisted works, but must disclose and disclaim non-human created portions, which means the scope of copyright registration covers only the human-created elements of the work. To give a simple example: if the text of a book is written by a human and the illustrations are generated by AI, the original text portion enjoys copyright protection, while the illustrations are unprotected. When human creation elements and AI-generated elements are difficult to segregate, determinations become far more complex.

The US currently does not set a bright-line standard specifying how much human input is required to obtain copyright protection. South Korea, however, now establishes a threshold: human creative input must account for at least 51% of the creation process.

This Policy Adjustment Has Not Yet Amended Statutory South Korean Law

Although KOMCA's policy change is significant, it has not altered existing South Korean copyright statutory law. In fact, South Korean National Assembly member Kim Jae-won has publicly criticized this policy adjustment, pointing out that KOMCA has no authority to unilaterally modify the existing Copyright Act. In short, although the Association allows certain AI-assisted works to undergo registration, the South Korean National Assembly has not yet amended the Copyright Act, meaning these registered works do not automatically gain statutory copyright protection solely by virtue of registration.

Key Takeaways

KOMCA's policy adjustment is practically actionable, yet demands strict compliance. When applying for copyright registration in South Korea, music creators who utilize AI can now complete registration, provided that humans play a substantial and dominant role in creation and that application filings fully and truthfully reconstruct the work's creation process.

For enterprises and copyright holders, evidence retention and truthful disclosure have become critical steps in the creation and registration workflows. It is recommended to contemporaneously retain complete sets of records throughout the song creation process, preserve project files and modification history, and ensure that attributions, revenue splits, registration filings, and raw source materials remain strictly consistent. False or careless declarations carry tangible risks, including royalty withholding, fund clawbacks, and even the termination of trust agreements.

Practitioners and copyright holders should continuously monitor discussions among KOMCA, the South Korean National Assembly, and the Ministry of Culture, Sports and Tourism to track whether subsequent amendments to the South Korean Copyright Act materialize.