PERLINDUNGAN HUKUM TERHADAP KARYA CIPTA BERUPA GAMBAR YANG DIHASILKAN OLEH ARTIFICIAL INTELLIGENCE DI INDONESIA (STUDY KOMPRATIF NEGARA INGGRIS, JEPANG DAN INDONESIA)

This study aims to examine and analyze the forms of legal protection granted to copyrighted works in the form of images generated by Artificial Intelligence (AI) within the Indonesian legal system, while also comparing these provisions with those in the United Kingdom and Japan to assess the urgency of copyright law reform in the digital era. Employing a normative juridical research method, the study adopts both a statutory approach and a comparative law approach, drawing upon primary legal materials such as Indonesia’s Law No. 28 of 2014 on Copyright, the United Kingdom’s Copyright, Designs and Patents Act 1988, and Japan’s Copyright Act, as well as secondary sources including academic literature and prior research. The data were analyzed qualitatively through the stages of data reduction, data presentation, and conclusion drawing, supported by triangulation techniques to ensure the validity of findings. The results indicate that the United Kingdom attributes copyright ownership to the individual who organizes or directs the creative process; Japan, on the other hand, rejects recognition of works generated entirely by AI due to the absence of human expression; whereas Indonesia lacks explicit regulation on this matter, resulting in a rechtvacuum and legal uncertainty for creative industry stakeholders. Based on the comparative analysis, Indonesia is advised to adopt a hybrid model that grants limited recognition to AI-generated works, provided there is demonstrable human creative intervention, thereby maintaining a balance between legal protection and technological innovation. Consequently, copyright law reform emerges as a normative necessity to ensure legal certainty, justice, and utility in the age of artificial intelligence.