Jurisdiction Comparison Matrix
How 11 surveyed jurisdictions protect data across 6 legal mechanisms, based on the Data as an IP Asset Part II report (INTA Data Protection Committee, 2024/25). No jurisdiction currently treats data as a standalone IP right.
AI-Generated Protection Levels
The Strong / Moderate / Limited / None ratings are assessed by AI based on the Data as an IP Asset Part II report (INTA Data Protection Committee, 2024/25). They are indicative only and do not constitute legal advice. Always consult the underlying report and qualified legal counsel for jurisdiction-specific guidance. Click any badge to view the source analysis.
Showing 11 of 11 jurisdictions
Jurisdiction | Recent Changes | ||||||
|---|---|---|---|---|---|---|---|
United States Americas | Thaler v. Perlmutter (D.C. Cir. 2025) reaffirmed no copyright for AI-generated works. CCPA amendments expand personal data rights. | ||||||
European Union Europe | EU AI Act entered into force August 2024, with phased application. EU Data Act 2023 introduces mandatory data sharing for IoT data. | ||||||
United Kingdom Europe | Data (Use and Access) Act 2025 largely entered force 5 February 2026. Introduces automated decision-making reforms and electronic marketing changes. Further provisions phasing in during 2026. | ||||||
Canada Americas | Criminal Code amended 2022 to criminalize trade secret theft. AIDA (AI and Data Act) under parliamentary consideration. | ||||||
Australia Asia-Pacific | Privacy Act 1988 significantly amended in 2024, strengthening individual rights and increasing penalties. | ||||||
Brazil Americas | LGPD enforcement strengthened; ANPD (data protection authority) increasingly active. AI regulation framework under development. | ||||||
China Asia-Pacific | Generative AI Service Regulations (2023) require training data compliance. Cross-border data transfer rules under PIPL/DSL impose significant restrictions on data exports. | ||||||
India Asia-Pacific | Digital Personal Data Protection Act (DPDPA) enacted 2023; implementing rules expected 2025–2026. | ||||||
Kenya Africa | Data Protection Act 2019 implemented; Office of the Data Protection Commissioner increasingly active. | ||||||
Mexico Americas | Digital economy reforms ongoing. LFPDPPP enforcement by INAI continues to develop. | ||||||
Nigeria Africa | Copyright Act amended 2022. Nigeria Data Protection Act (NDPA) enacted 2023, establishing Nigeria Data Protection Commission (NDPC). |
Source: Data as an IP Asset Part II, INTA Data Protection Committee, Best Practices Subcommittee, 2024/25. Analysis covers AU, BR, CA, CN, EU, IN, KE, MX, NG, UK, US.