The short answer
Three things decide whether a contractor’s IP transfer holds up: the form the law requires (often written form, sometimes on pain of nullity), the kind of signature that satisfies that form electronically, and the terms the agreement must spell out, such as each use, the duration and the territory.
A click-to-sign agreement with a simple electronic signature works in the United States, the United Kingdom and many other countries. It does not meet a written-form requirement in countries such as Poland, where only a qualified electronic signature counts as written form electronically. Where the agreement is silent, defaults can shrink the transfer: India deems an assignment to last five years and to cover India only, and Brazil limits it to five years, Brazil and the uses that existed at signing.
Where a click-to-sign IP transfer may not be enough
In these 16 countries the form rules for a copyright transfer can defeat a simple click-to-sign: the transfer must be in writing, and in some also registered or notarized. The safe electronic route is a qualified or certified signature, and the table notes the exceptions, such as Georgia, where any electronic signature the parties agreed to in advance counts.
| Country | Rule | What to use |
|---|---|---|
| Estonia | Written for a transfer or exclusive license, or it is void (Copyright Act § 49(1), Civil Code General Part § 83(1)) | Qualified e-signature such as ID-card, Mobile-ID or Smart-ID, or wet ink. Don’t rely on a click (Civil Code General Part § 80) |
| Poland | Written, or the transfer is void, and the same applies to an exclusive license (Copyright Act Art. 53, 67(5)) | Qualified electronic signature or wet ink only. A click or typed name does not count (Civil Code Art. 78^1) |
| Portugal | A public deed for a total transfer, notarially recognized signatures for a partial one, or it is void (Copyright Code Art. 43-44) | Qualified e-signature for plain written form. Assume it can’t replace a public deed or notarial recognition (Decree-Law 12/2021 Art. 3) |
| Azerbaijan | A written author’s contract, or the transfer is invalid (Copyright Law Art. 31(4), Civil Code Art. 329.1) | Enhanced e-signature such as ASAN Imza or SIMA, or wet ink. A simple one is uncertain (E-Signature Law Art. 3.2) |
| Georgia | Written, or the agreement is void (Copyright Law Art. 42, Civil Code Art. 59(1)) | Qualified e-signature or wet ink. A simple e-signature counts only if the parties agreed in advance (Electronic Documents Law Art. 3(8)) |
| Serbia | Written, or the contract probably has no legal effect (Copyright Law Art. 67(3), Law on Obligations Art. 70) | Qualified e-signature from a provider registered in Serbia, or wet ink. Whether a click counts is unsettled (E-Document Law Art. 50) |
| Turkey | Written, with each right listed separately, or it has no effect (Law 5846 Art. 52, Code of Obligations Art. 12(2)) | Turkish secure e-signature (e-imza) or wet ink. An EU qualified signature is not automatically recognized (Law 5070 Art. 5, 14) |
| Ukraine | Written (including electronic) form, or the contract is null and void (Civil Code Art. 1107(2), Law 2811-IX Art. 48(2)) | Qualified e-signature (KEP, such as Diia.Signature) or wet ink. A click or typed name is risky (Law 2155-VIII Art. 18(6)) |
| Bangladesh | A signed written deed, or the assignment is not valid, and the deed must be registered (Copyright Act 2023 s.16(6), 17) | Digital signature from a licensed certifying authority, or wet ink. A click or typed name may not count (ICT Act s.2(1), 7) |
| India | Written and signed by the contractor, or the assignment is not valid (Copyright Act 1957 s.19(1)) | Digital signature certificate or Aadhaar eSign, or wet ink. A click or typed name does not count (IT Act s.2(1)(ta), 5) |
| Nepal | A written agreement, though the section does not expressly require a signature (Copyright Act 2002 s.24(1)) | Where a signature is needed, only a licensed PKI digital signature counts, not a click (Electronic Transactions Act s.5) |
| Vietnam | In writing, and only economic rights and the publication right can be assigned (Law on Intellectual Property Art. 45, 46(1)) | A licensed digital signature equals a handwritten one, while a click is valid but weaker evidence (Law on E-Transactions Art. 23) |
| Kenya | Written and signed, or it has no effect, and it is not valid until recorded with KECOBO (Copyright Act s.33(3), 33(3A)) | Advanced or certified e-signature, or wet ink. A click or typed name does not count (Information and Communications Act s.83P) |
| South Africa | Written and signed by the contractor, or the assignment has no effect (Copyright Act 98 of 1978 s.22(3)) | Accredited advanced e-signature or wet ink only. A click or typed name does not count (Electronic Communications and Transactions Act s.13(1)) |
| Argentina | Written, and read literally, an assignment of a literary, scientific or musical work is invalid unless registered (Law 11.723 Art. 53) | Certified firma digital equals a handwritten signature. A click or typed name must be proven if disowned (Law 25.506 Art. 3, 5) |
| Chile | Public instrument or notarized private instrument, recorded in the Intellectual Property Registry within 60 days (Law 17.336 Art. 73) | Notarial authorization given electronically with an accredited advanced e-signature, or on paper. A click alone does not count (Law 19.799 Art. 3-4) |
Sources:Riigi Teataja: Copyright Act (English translation of the version in force from 01.10.2025)Riigi Teataja: Autoriõiguse seadus (authentic Estonian text, RT I, 12.07.2025, 9), § 49Riigi Teataja: General Part of the Civil Code Act (English, in force from 01.01.2025), § 78-80, 83eIDAS Regulation (EU) 910/2014, consolidated, Art. 25 (EUR-Lex)Copyright Act, consolidated text Dz.U. 2025 poz. 24 (ISAP record)Civil Code, consolidated text Dz.U. 2026 poz. 795 (Art. 73, 78, 78^1), official PDFCDADC consolidated (Arts. 14, 15, 41-44-F, 48, 56), Diário da RepúblicaDecreto-Lei 12/2021, Art. 3 (electronic documents and signatures), Diário da RepúblicaDecreto-Lei 252/94 (computer programs), Art. 3, Diário da RepúblicaLaw of Azerbaijan No. 115-IQ on Copyright and Related Rights (Arts. 13, 14, 15, 28, 30, 31), e-qanun.az full textCivil Code of Azerbaijan (Arts. 329, 331), e-qanun.az full textLaw No. 602-IIQ on Electronic Signature and Electronic Document, Art. 3, e-qanun.az full textLaw of Georgia on Copyright and Related Rights (Arts. 16, 17, 18, 36-43), Matsne (English, consolidated to 09/12/2025)Civil Code of Georgia (Arts. 59, 68, 69), Matsne (English)Law of Georgia on Electronic Documents and Electronic Trust Services, Art. 3-4, latest consolidated (09/02/2023), Matsne GeorgianSame law, English translation (initial 2017 version, Art. 3(1),(8) and 4(2) wording unchanged), MatsneLegal Information System of the Republic of Serbia: Law on Copyright and Related Rights (104/2009 ... 66/2019), Art. 60-72, 95, 98Legal Information System: Law on Electronic Document, Electronic Identification and Trust Services (94/2017, 52/2021), Art. 7, 50Legal Information System: Law on Obligations, Art. 67-73Ministry of Culture and Tourism, Directorate General of Copyright: Law 5846 (FSEK) consolidated textDirectorate General of Copyright: English translation of Law 5846 (2026, unofficial)Grand National Assembly (TBMM): Electronic Signature Law 5070, Art. 4, 5, 14 (as adopted)TBMM: Turkish Code of Obligations 6098, Art. 12-15 (as adopted)Law of Ukraine No. 2811-IX On Copyright and Related Rights (Arts. 11, 12, 14, 15, 48-50), zakon.rada.gov.uaCivil Code of Ukraine (Arts. 207, 218, 423, 430, 1107, 1112, 1113), zakon.rada.gov.uaLaw No. 2155-VIII On Electronic Identification and Electronic Trust Services, Art. 18(6), zakon.rada.gov.uaLaw No. 675-VIII On Electronic Commerce, Arts. 1, 11, 12, zakon.rada.gov.uaCopyright Act 2023 (Bangla, bdlaws), ss.15-18, 20, 78Information and Communication Technology Act 2006 (Bangla, bdlaws), ss.2(1), 5-7Copyright Act 1957 (Copyright Office PDF), ss.17-19A, 57Information Technology Act 2000 (updated, India Code), ss.1(4), 2(1)(ta), 3A, 4, 5, 10A, First ScheduleCopyright Act 2059 (2002), English (Copyright Registrar's Office), ss.6, 8, 24Electronic Transactions Act 2063 (2008), English (Trade and Export Promotion Centre, Govt of Nepal), ss.2(o), 4, 5, 77Law on Intellectual Property, consolidated text 155/VBHN-VPQH (Official Gazette, Sep 2025), Arts. 19, 39, 45, 46Copyright Office: articles amended by Law 131/2025/QH15 (Arts. 39, 45, 46 not amended)Law on E-Transactions 2023, consolidated 42/VBHN-VPQH (Official Gazette, Mar 2025), Arts. 1, 9, 22, 23Copyright Act Cap. 130 (Rev. 2022), KECOBO PDF, ss.31-33Kenya Information and Communications Act (Rev. 2020), Communications Authority PDF, ss.83B, 83G, 83J, 83O, 83PCopyright Act 98 of 1978 (Government Gazette, gov.za), ss.20, 22Copyright Act 1978 as amended to Act 9 of 2002 (WIPO Lex), s.21Electronic Communications and Transactions Act 25 of 2002 (gov.za), ss.1, 4, 12, 13Copyright Amendment Bill B13-2017 status (Parliament)Ley 11.723 (InfoLEG, updated text), Arts. 4, 51-53Ley 25.506 Firma Digital (InfoLEG, updated text), Arts. 2, 3, 5, 6Código Civil y Comercial (InfoLEG), Arts. 286-288, 1618Ley 17.336 Propiedad Intelectual (BCN LeyChile), Arts. 8, 16, 73Ley 19.799 documentos y firma electrónica (BCN LeyChile), Arts. 2-5
European Union
EU law sets the legal effect of electronic signatures but leaves copyright contracts to each member state, so the form a transfer needs, and the signature that meets it, differ by country.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Bulgaria | No general form since Dec 2023, but an exclusive grant must be express and written, or it is deemed non-exclusive (Art. 36(4)) | Qualified e-signature, or a simple one if the parties agreed it has handwritten effect (Electronic Document Act Art. 13(4)) | Exclusivity in writing, term, territory, each use and a fair fee (Copyright Act Art. 36(1), 36(4)) | With no term the grant lasts 3 years, and with no territory it covers only the user’s country (Art. 36(5)-(6)) |
| Estonia | Written for a transfer or exclusive license, or it is void (Copyright Act § 49(1), Civil Code General Part § 83(1)) | Qualified e-signature such as ID-card, Mobile-ID or Smart-ID, or wet ink. Don’t rely on a click (Civil Code General Part § 80) | The work, rights transferred, exclusivity and sublicensing right, manner of use, territory, term and start of use (Copyright Act § 48^1(1)) | The author may cancel a transfer if the work isn’t used within 2 years, or up to 5 if agreed (§ 49^3) |
| France | In writing (IP Code Art. L131-2), which courts generally treat as proof, not a validity rule | Any reliable e-signature. Only a qualified one is presumed reliable, so an advanced or qualified one is safer (Civil Code Art. 1367) | Each right separately, with its extent, purpose, place and duration, or the author can seek to annul it (IP Code Art. L131-3) | A global assignment of future works is void, and rights not mentioned are not transferred (IP Code Art. L131-1, L131-3) |
| Germany | No form for specific deliverables. Unknown uses and future works named only by type need writing, or are void (UrhG §31a, §40) | Click or typed signing for specific deliverables. Where writing applies, a qualified e-signature by each party or wet ink (BGB §126a) | Each use, exclusivity, territory and term, plus consent to onward transfer, sublicensing and modification (UrhG §31, §34, §35, §39) | Copyright itself can’t be transferred, and a grant covers only listed uses or what the contract’s purpose requires (UrhG §29(1), §31(5)) |
| Italy | Written only to prove the transfer, which is valid without it (Copyright Law 633/1941 Art. 110) | Advanced or qualified e-signature, or a SPID-identified process. A plain click is assessed case by case (CAD Art. 20(1-bis)) | Each right by name, including adaptation and AI training, plus territory, duration and acceptance of modifications (Art. 119, 22) | Adaptation and modification rights don’t pass unless expressly agreed, and rights from later laws are excluded (Art. 119) |
| Lithuania | Written, though a contract without writing is not void, only unprovable by witnesses (Copyright Law Art. 42(1), Civil Code Art. 1.93) | Qualified e-signature such as Smart-ID or Mobile-ID, or a simple one under a prior written agreement (Law XIII-1120 Art. 5(1)) | The work, each mode of use, license type, territory, term, fee and payment terms, and dispute and liability terms (Art. 40(1)) | Even a transfer of all rights covers only listed uses, and no stated territory means Lithuania only (Art. 40(2)-(3)) |
| Netherlands | A written agreement and a deed of transfer, or copyright does not pass (Copyright Act Art. 2(3), Civil Code 3:95) | Any sufficiently reliable e-signature. A platform signature with ID checks and an audit trail usually suffices (Civil Code 3:15a) | Every power transferred, such as reproduction, adaptation, making available, AI training and sublicensing (Copyright Act Art. 2(3)) | Powers not named stay with the contributor, and a vague or overlong future-works clause is voidable (Art. 2(3), 25f(1)) |
| Poland | Written, or the transfer is void, and the same applies to an exclusive license (Copyright Act Art. 53, 67(5)) | Qualified electronic signature or wet ink only. A click or typed name does not count (Civil Code Art. 78^1) | The works, each field of exploitation, the right to permit derivative works and the fee (Art. 41(2), 46) | Fields of exploitation not listed stay with the contributor, and only fields known at signing can be covered (Art. 41(2), 41(4)) |
| Portugal | A public deed for a total transfer, notarially recognized signatures for a partial one, or it is void (Copyright Code Art. 43-44) | Qualified e-signature for plain written form. Assume it can’t replace a public deed or notarial recognition (Decree-Law 12/2021 Art. 3) | For a total transfer the work and price, and for a partial one each right, time, place and price (Art. 43(3), 44) | Commissioned work is presumed to belong to the creator unless agreed, and a partial transfer covers only named uses (Art. 14(2), 43(1)) |
| Romania | In writing, the only way to prove the assignment, but its absence does not void it (Law 8/1996 Art. 43) | Advanced or qualified e-signature, or wet ink. A simple one alone is not enough for an individual contractor (Law 214/2024 Art. 4(9)) | Each right with its mode of use, duration, territory and the fee, and exclusivity stated expressly (Art. 42(1), 40(4)) | Commissioned work stays with the contributor unless the contract says otherwise, and assigning all future works is void (Art. 47(1), 42(2)) |
| Spain | In writing, not on pain of nullity. The author may terminate if it isn’t formalized after formal demand (IP Law Art. 45) | Click or typed signing works, as electronic form meets written form. A qualified one gives the strongest evidence (Law 34/2002 Art. 23(3)) | Each right and mode of exploitation, duration and territory, and exclusivity stated expressly (IP Law Art. 43(1), 48) | No stated duration limits it to 5 years, and no territory to the country where it was made (IP Law Art. 43(2)) |
Sources:State Gazette No. 100/2023: Act amending the Copyright and Related Rights Act (§ 18 repeals Art. 37(2))eIDAS Regulation (EU) 910/2014, consolidated, Art. 25 (EUR-Lex)Riigi Teataja: Copyright Act (English translation of the version in force from 01.10.2025)Riigi Teataja: Autoriõiguse seadus (authentic Estonian text, RT I, 12.07.2025, 9), § 49Riigi Teataja: General Part of the Civil Code Act (English, in force from 01.01.2025), § 78-80, 83CPI L131-2 (writing), LégifranceCPI L131-3 (separate mention, extent, purpose, place, duration), LégifranceCPI L131-1 to L131-9 (section), LégifranceCode civil Art. 1367 (electronic signature), LégifranceUrheberrechtsgesetz (UrhG) full text, §§13, 14, 29, 31, 31a, 32, 32a, 32b, 34, 35, 39, 40, 43, 69bBGB §125 (nullity for missing form)BGB §126 (written form)BGB §126a (electronic form = QES)L. 633/1941 Art. 110 (transfer proven in writing), NormattivaL. 633/1941 Art. 119 (scope of transfer), NormattivaL. 633/1941 Art. 107 (transfer, adequate and proportionate remuneration), NormattivaCAD D.Lgs. 82/2005 Art. 20 (electronic documents and written form), NormattivaRegister of Legal Acts (e-TAR): Law on Copyright and Related Rights VIII-1185, consolidated versionse-TAR: Civil Code consolidated text 2026-09-27 to 2026-12-08 (Art. 1.73, 1.93) (PDF)e-TAR: Law on Electronic Identification and Trust Services XIII-1120, consolidated from 2024-10-18, Art. 5 (PDF)Auteurswet, current version (in force from 1 Jan 2026), wetten.overheid.nlStaatsblad 2025, 352: Wet versterking auteurscontractenrecht (new Art. 2(3))Burgerlijk Wetboek Book 3 (Arts. 3:15a, 3:39, 3:95)Burgerlijk Wetboek Book 6 (Art. 6:227a)Copyright Act, consolidated text Dz.U. 2025 poz. 24 (ISAP record)Civil Code, consolidated text Dz.U. 2026 poz. 795 (Art. 73, 78, 78^1), official PDFCDADC consolidated (Arts. 14, 15, 41-44-F, 48, 56), Diário da RepúblicaDecreto-Lei 12/2021, Art. 3 (electronic documents and signatures), Diário da RepúblicaDecreto-Lei 252/94 (computer programs), Art. 3, Diário da RepúblicaWIPO Lex: Law No. 8/1996 on copyright and related rights, consolidated Romanian text amended up to Law 69/2022Chamber of Deputies legislative database: Law 8/1996 record (republication MO 489/2018 and amendments incl. Law 69/2022)Chamber of Deputies: Law 214/2024 on electronic signatures, record (MO 647/8 Jul 2024, repeals Law 455/2001 from 8 Oct 2024)Chamber of Deputies: Law 214/2024, final text adopted by Parliament (Art. 3-5, Art. 35)TRLPI (RDL 1/1996) consolidated, BOE (Arts. 8, 14, 43-51, 97)Ley 34/2002 LSSI, Art. 23 (electronic contracts satisfy written form), BOELey 6/2020 on electronic trust services, Art. 3, BOE
Ukraine, Turkey, the Caucasus, Central Asia and Serbia
Most of these countries require copyright transfers in writing, and several void a transfer that is not, which makes the type of electronic signature decisive.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Armenia | Written, or a deal with a foreign client may be invalid (Copyright Law Art. 40(8), Civil Code Art. 298(3)) | Click or typed signing with solid identity checks generally works. A digital signature is stronger (Civil Code Art. 450(3)) | The scope of rights, ways of use, term, fee and payment timing and procedure (Art. 40(1)) | Rights not provided for stay with the contributor, and a contract silent on territory covers Armenia only (Art. 40(3)-(4)) |
| Azerbaijan | A written author’s contract, or the transfer is invalid (Copyright Law Art. 31(4), Civil Code Art. 329.1) | Enhanced e-signature such as ASAN Imza or SIMA, or wet ink. A simple one is uncertain (E-Signature Law Art. 3.2) | Each use, term, territory, exclusivity, the royalty for each use and payment terms (Art. 30(4), 31(1)) | Rights are non-exclusive unless stated, and a contract silent on territory covers Azerbaijan only (Art. 30(4), 31(1)) |
| Georgia | Written, or the agreement is void (Copyright Law Art. 42, Civil Code Art. 59(1)) | Qualified e-signature or wet ink. A simple e-signature counts only if the parties agreed in advance (Electronic Documents Law Art. 3(8)) | Delivery, acceptance and royalty terms (Art. 43), and it is safer to add each use, term and territory (Art. 40(1)) | Future works can’t be transferred in advance, and a license silent on territory covers Georgia only (Art. 43(7), 40(5)) |
| Kazakhstan | Signed in writing by both parties, or a foreign client’s deal may be void (Copyright Law Art. 31(1), Civil Code Art. 153(3)) | Kazakh digital signature (NCA RK or eGov) or wet ink. A click or typed name is weak evidence (Digital Code Art. 49(2)) | Each use, term, territory, the fee for each use, and payment terms and deadlines (Art. 32(1)) | Uses not expressly transferred stay with the contributor, and uses unknown at signing can’t be transferred (Art. 32(4)-(5)) |
| Moldova | In writing, which is the only proof of an assignment, and a license without writing is void (Law 230/2022 Art. 30(8), 31(3)) | Qualified e-signature or wet ink, or a simple one under a prior written e-signature agreement (Law 124/2022 Art. 40) | The rights transferred, duration and extent of use, and the fee, or a party may seek rescission (Art. 30(6)) | Under a commission contract, economic rights stay with the contributor unless the contract says otherwise (Art. 34(1)) |
| Serbia | Written, or the contract probably has no legal effect (Copyright Law Art. 67(3), Law on Obligations Art. 70) | Qualified e-signature from a provider registered in Serbia, or wet ink. Whether a click counts is unsettled (E-Document Law Art. 50) | The parties, the work, the rights transferred, exclusivity, payment if agreed, and content, territory and time limits (Art. 69, 62) | In doubt, fewer rights are deemed transferred, and assigning all future works or unknown uses is void (Art. 68, 66) |
| Turkey | Written, with each right listed separately, or it has no effect (Law 5846 Art. 52, Code of Obligations Art. 12(2)) | Turkish secure e-signature (e-imza) or wet ink. An EU qualified signature is not automatically recognized (Law 5070 Art. 5, 14) | Each economic right transferred, listed separately, such as reproduction, adaptation, distribution and making available (Law 5846 Art. 52) | A transfer of a work not yet created or completed is void, and adaptations aren’t covered unless agreed (Art. 48, 55) |
| Ukraine | Written (including electronic) form, or the contract is null and void (Civil Code Art. 1107(2), Law 2811-IX Art. 48(2)) | Qualified e-signature (KEP, such as Diia.Signature) or wet ink. A click or typed name is risky (Law 2155-VIII Art. 18(6)) | The work, the economic rights and uses transferred, and the fee or a statement that it is free (Art. 48(2)) | A transfer for any term other than the full copyright term is void, and rights not named are not transferred (Art. 49(1)-(2)) |
Sources:RA Law HO-142-N on Copyright and Related Rights (Arts. 12, 13, 33, 38-40), ARLIS official incorporationRA Civil Code (Arts. 296, 298, 450), ARLIS latest edition (in force from 30.08.2026)RA Law on Electronic Document and Electronic Digital Signature (Arts. 1, 4), ARLIS latest editionLaw of Azerbaijan No. 115-IQ on Copyright and Related Rights (Arts. 13, 14, 15, 28, 30, 31), e-qanun.az full textCivil Code of Azerbaijan (Arts. 329, 331), e-qanun.az full textLaw No. 602-IIQ on Electronic Signature and Electronic Document, Art. 3, e-qanun.az full textLaw of Georgia on Copyright and Related Rights (Arts. 16, 17, 18, 36-43), Matsne (English, consolidated to 09/12/2025)Civil Code of Georgia (Arts. 59, 68, 69), Matsne (English)Law of Georgia on Electronic Documents and Electronic Trust Services, Art. 3-4, latest consolidated (09/02/2023), Matsne GeorgianSame law, English translation (initial 2017 version, Art. 3(1),(8) and 4(2) wording unchanged), MatsneLaw of RK No. 6 On Copyright and Related Rights (Arts. 14, 15, 30-33), AdiletCivil Code of RK, General Part (Arts. 152, 153), AdiletCivil Code of RK, Special Part (Arts. 965-967), AdiletDigital Code of RK No. 255-VIII of 9 Jan 2026 (Arts. 46, 47, 49, 62), AdiletLaw No. 230/2022 on Copyright and Related Rights (Arts. 10, 30, 31, 33-35, 39), WIPO Lex (Romanian and English texts, 2022 version)AGEPI (State Agency on IP) copyright legislation page linking the current legis.md textLegal Information System of the Republic of Serbia: Law on Copyright and Related Rights (104/2009 ... 66/2019), Art. 60-72, 95, 98Legal Information System: Law on Electronic Document, Electronic Identification and Trust Services (94/2017, 52/2021), Art. 7, 50Legal Information System: Law on Obligations, Art. 67-73Ministry of Culture and Tourism, Directorate General of Copyright: Law 5846 (FSEK) consolidated textDirectorate General of Copyright: English translation of Law 5846 (2026, unofficial)Grand National Assembly (TBMM): Electronic Signature Law 5070, Art. 4, 5, 14 (as adopted)TBMM: Turkish Code of Obligations 6098, Art. 12-15 (as adopted)Law of Ukraine No. 2811-IX On Copyright and Related Rights (Arts. 11, 12, 14, 15, 48-50), zakon.rada.gov.uaCivil Code of Ukraine (Arts. 207, 218, 423, 430, 1107, 1112, 1113), zakon.rada.gov.uaLaw No. 2155-VIII On Electronic Identification and Electronic Trust Services, Art. 18(6), zakon.rada.gov.uaLaw No. 675-VIII On Electronic Commerce, Arts. 1, 11, 12, zakon.rada.gov.ua
United Kingdom and Ireland
An assignment must be in writing and signed by the contractor, and a simple electronic signature meets that requirement.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Ireland | Written and signed by the contractor, or the assignment is not effective (Copyright and Related Rights Act 2000 s.120(3)) | A simple e-signature such as DocuSign works if the company consents to it (Electronic Commerce Act 2000 s.13) | The works, present words of assignment covering future copyright, and any limits by acts or period (CRRA s.120(2), s.121) | The author can revoke an exclusive license or transfer of a work that is not exploited (S.I. 567/2021 Reg. 29) |
| United Kingdom | Written and signed by the contractor, or the assignment is not effective (CDPA 1988 s.90(3)) | A simple e-signature, such as click-to-sign or a typed name, is generally enough (Electronic Communications Act 2000 s.7) | The works, present words of assignment covering future copyright, and any limits by acts or period (CDPA s.90(2), s.91) | Ambiguous grants may be read narrowly or as a license, and moral rights need a signed written waiver (CDPA s.87) |
Sources:CRRA 2000 s.120 (assignment in writing signed)CRRA 2000 s.121 (future copyright)Electronic Commerce Act 2000 s.13 (signatures)S.I. No. 567/2021 (DSM Regulations), Part 6 remunerationCDPA 1988 s.90 (assignment in writing signed)CDPA 1988 s.91 (future copyright)CDPA 1988 s.87 (waiver of moral rights)Electronic Communications Act 2000 s.7
South Asia
Copyright laws modeled on India’s require a signed written assignment and fill gaps with short defaults for duration and territory.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Bangladesh | A signed written deed, or the assignment is not valid, and the deed must be registered (Copyright Act 2023 s.16(6), 17) | Digital signature from a licensed certifying authority, or wet ink. A click or typed name may not count (ICT Act s.2(1), 7) | The work, rights assigned, duration, geographical scope, and the royalty, advance or lump sum (s.17(2)-(3)) | No stated term means 5 years, no territory means Bangladesh, and rights unused for 1 year lapse (s.17(2), 17(4)) |
| India | Written and signed by the contractor, or the assignment is not valid (Copyright Act 1957 s.19(1)) | Digital signature certificate or Aadhaar eSign, or wet ink. A click or typed name does not count (IT Act s.2(1)(ta), 5) | The work, rights assigned, duration, territory, royalty or other consideration, and any media not yet in use (s.18(1), 19) | No stated term means 5 years, no territory means India, and rights unused for 1 year lapse (s.19(4)-(6)) |
| Nepal | A written agreement, though the section does not expressly require a signature (Copyright Act 2002 s.24(1)) | Where a signature is needed, only a licensed PKI digital signature counts, not a click (Electronic Transactions Act s.5) | None prescribed, and the company may exercise only the rights expressly transferred (s.24(3)) | Moral rights can’t be transferred during the author’s life, and the Act has no waiver (s.8(2), 24(2)) |
| Pakistan | Written and signed by the contractor, or the assignment is not valid (Copyright Ordinance 1962 s.15) | A simple e-signature is legally enough. An advanced one only adds evidential weight (Electronic Transactions Ordinance 2002 s.7, 9) | No mandatory contents, unlike India, but naming the works and rights transferred is still safer | An author’s assignment has effect for at most 10 years after the year it is made, then copyright reverts (s.14(1)) |
| Sri Lanka | Written and signed by both the contractor and the company (Intellectual Property Act 2003 s.16(2)) | A simple e-signature is acceptable, but both parties must sign (Electronic Transactions Act 2006 s.7) | No set list, but name each right and use, as rights not expressly referred to are not included (s.16(3)) | Moral rights can’t be transferred during the author’s life, and a waiver must specify the rights and circumstances (s.10(2)-(3)) |
Sources:Copyright Act 2023 (Bangla, bdlaws), ss.15-18, 20, 78Information and Communication Technology Act 2006 (Bangla, bdlaws), ss.2(1), 5-7Copyright Act 1957 (Copyright Office PDF), ss.17-19A, 57Information Technology Act 2000 (updated, India Code), ss.1(4), 2(1)(ta), 3A, 4, 5, 10A, First ScheduleCopyright Act 2059 (2002), English (Copyright Registrar's Office), ss.6, 8, 24Electronic Transactions Act 2063 (2008), English (Trade and Export Promotion Centre, Govt of Nepal), ss.2(o), 4, 5, 77Copyright Ordinance 1962 (Pakistan Code PDF), ss.13-15, 62Electronic Transactions Ordinance 2002 (Pakistan Code PDF), ss.2(n), 3, 4, 7, 9, 31Intellectual Property Act No. 36 of 2003 (NIPO PDF), ss.10, 14, 16Electronic Transactions Act No. 19 of 2006 (ICTA PDF), ss.7, 23
Southeast Asia
Written assignments are the norm, and local electronic transaction laws decide which electronic signatures count.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Indonesia | A written agreement, one of the listed means of transfer (Copyright Law 28/2014 Art. 16(2)(e)) | A certified e-signature from an Indonesian provider is advisable. A simple one is valid but harder to prove (ITE Law Art. 11) | None prescribed, but add a clause that copyright in commissioned work belongs to the company (Art. 36) | Books, other written works and songs sold outright or with no time limit revert to the author after 25 years (Art. 18) |
| Malaysia | Written, or the assignment or license has no effect. No signature is expressly required (Copyright Act 1987 s.27(3)) | A simple platform e-signature is acceptable, and the Digital Signature Act 1997 offers a certified option (Electronic Commerce Act 2006 s.9) | None prescribed. An assignment may be limited by acts, period or geography, and may cover future works (s.27(2), 27(6)) | Presenting the work without naming the author, or distorting it, needs the author’s consent, so get it in writing (s.25) |
| Philippines | Written indication of intent, or copyright is not deemed assigned. No express signature or notarization requirement (IP Code Sec. 180.2) | A platform e-signature with ID checks, consent and an audit trail is adequate (E-Commerce Act RA 8792 s.8) | None prescribed. State the scope expressly, because the company gets only rights within the assignment’s scope (Sec. 180.1) | Copyright in commissioned work stays with the contributor unless the contract stipulates otherwise in writing (Sec. 178.4) |
| Thailand | Written and signed by both the contractor and the company (Copyright Act B.E. 2537 s.17) | A simple e-signature can qualify if it identifies the signer and is reliable, and both parties must e-sign (Electronic Transactions Act s.9) | No list beyond both signatures, but state the duration as the full copyright term (s.17) | An assignment that states no duration is deemed to last only 10 years (s.17) |
| Vietnam | In writing, and only economic rights and the publication right can be assigned (Law on Intellectual Property Art. 45, 46(1)) | A licensed digital signature equals a handwritten one, while a click is valid but weaker evidence (Law on E-Transactions Art. 23) | Both parties’ names and addresses, basis for assignment, price and payment, rights and obligations, and breach liability (Art. 46(1)) | Moral rights other than publication can’t be assigned, and all co-owners must agree to an assignment (Art. 45(2)-(3)) |
Sources:Law 28/2014 on Copyright (DJKI PDF), Arts. 5, 16-18, 36, 76UU ITE 11/2008 (JDIH Komdigi PDF), Arts. 5, 6, 11UU 1/2024 second amendment to UU ITE (JDIH Komdigi), Arts. 5(4), 13, 17(2a), 18ACopyright Act 1987 (Act 332), AGC reprint as at 30 Jun 2022, ss.25-27Electronic Commerce Act 2006 (Act 658), AGC reprint, ss.2, 8, 9, ScheduleIP Code RA 8293 (LawPhil), Secs. 178, 180-182, 193, 195, 198RA 10372 (2013) amendments (LawPhil), Secs. 7-9, 17E-Commerce Act RA 8792 (LawPhil), ss.5(e), 6-9Copyright Act B.E. 2537, WIPO Lex (English; consolidated entry up to No. 5 B.E. 2565), ss.9, 10, 17, 18Electronic Transactions Act (No. 3) B.E. 2562, Office of the Council of State translation (MDES), amended ss.8-9Law on Intellectual Property, consolidated text 155/VBHN-VPQH (Official Gazette, Sep 2025), Arts. 19, 39, 45, 46Copyright Office: articles amended by Law 131/2025/QH15 (Arts. 39, 45, 46 not amended)Law on E-Transactions 2023, consolidated 42/VBHN-VPQH (Official Gazette, Mar 2025), Arts. 1, 9, 22, 23
Africa and the Middle East
Most of these laws require a signed written assignment, and some list exactly what it must state.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Egypt | Certified in writing, naming each right with its extent, purpose, duration and place of exploitation (Law 82/2002 Art. 149) | Certified e-signature from an ITIDA-licensed provider, or wet ink, is advisable. A plain click may fail the conditions (E-Signature Law Art. 18) | Each right, its extent and purpose, the duration and place of exploitation, and the remuneration (Art. 149-150) | Rights not explicitly transferred stay with the author, and any disposal of future works is void (Art. 149, 153) |
| Ghana | Written and signed by the contractor as copyright owner, or by someone they authorize (Copyright Act 2005 s.9(4)) | A reliable platform e-signature is acceptable, since the Act defines a digital signature broadly (Electronic Transactions Act 2008 s.10) | No list, but name every use, as a total transfer covers only the use the contract provides for (s.9(2)) | Moral rights can’t be transferred and there is no waiver provision, so the author keeps them (s.6, 9(1)) |
| Kenya | Written and signed, or it has no effect, and it is not valid until recorded with KECOBO (Copyright Act s.33(3), 33(3A)) | Advanced or certified e-signature, or wet ink. A click or typed name does not count (Information and Communications Act s.83P) | None listed for assignments. An assignment may be limited by acts, period or country (s.33(2)) | Agreements on future works not specified in detail can be terminated on 1 month’s notice after 3 years (s.33(8)) |
| Morocco | Written, for both assignments and licenses of economic rights (Law 2-00 Art. 41) | A simple e-signature is admissible, and a qualified one is safest for proof (Law 43-20 Art. 7) | No list, but define the rights, purposes, duration, territory and means of exploitation (Art. 42) | No territory limits it to the country of grant, and a global assignment of future works is void (Art. 39, 42) |
| Nigeria | Written, or the assignment or exclusive license has no effect. No signature is expressly required (Copyright Act 2022 s.30(3)) | A simple e-signature such as a click is acceptable (Evidence Act 2011 s.93, Cybercrimes Act 2015 s.17) | None prescribed. Identify the deliverables or project, because an assignment of all future works isn’t permitted (s.30(10)) | Copyright vests in the author unless an agreement provides otherwise, and moral rights can’t be transferred in the author’s life (s.28(1), 14(3)) |
| South Africa | Written and signed by the contractor, or the assignment has no effect (Copyright Act 98 of 1978 s.22(3)) | Accredited advanced e-signature or wet ink only. A click or typed name does not count (Electronic Communications and Transactions Act s.13(1)) | None prescribed. An assignment may be limited to some acts, part of the term or a country (s.22(2)) | Contractors own text, labels and code unless assigned. The Copyright Amendment Bill, not yet law, would change assignment rules (s.21(1)) |
Sources:Law 82/2002 on IP Rights (amended to Law 178/2020), WIPO Lex, Arts. 143-153, 175Law 15/2004 on E-Signature and ITIDA, WIPO Lex, Arts. 14, 15, 18, 19Copyright Act 2005 (Act 690), WIPO Lex, ss.6, 7, 9Electronic Transactions Act 2008 (Act 772), Cyber Security Authority PDF, ss.4, 5, 10Copyright Act Cap. 130 (Rev. 2022), KECOBO PDF, ss.31-33Kenya Information and Communications Act (Rev. 2020), Communications Authority PDF, ss.83B, 83G, 83J, 83O, 83PLaw 2-00 on Copyright, consolidated to Law 79-12 (French), WIPO Lex, Arts. 9, 33, 35, 39-42Law 43-20 on trust services for electronic transactions (DGSSI, BO 6970), Arts. 4-7Copyright Act 2022 (Nigerian Copyright Commission PDF), ss.14, 28, 30Copyright Act 98 of 1978 (Government Gazette, gov.za), ss.20, 22Copyright Act 1978 as amended to Act 9 of 2002 (WIPO Lex), s.21Electronic Communications and Transactions Act 25 of 2002 (gov.za), ss.1, 4, 12, 13Copyright Amendment Bill B13-2017 status (Parliament)
Latin America
Latin American copyright laws protect authors strongly: transfers must be written, are read narrowly, and in some countries are limited in time.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Argentina | Written, and read literally, an assignment of a literary, scientific or musical work is invalid unless registered (Law 11.723 Art. 53) | Certified firma digital equals a handwritten signature. A click or typed name must be proven if disowned (Law 25.506 Art. 3, 5) | No statutory list in Law 11.723, so it is safer to name the work, each right, territory and term | The assignee may not alter the work’s title, form or content, and moral rights can’t be waived (Art. 51-52) |
| Brazil | Always in writing, and a total and definitive transfer needs a written stipulation in the contract (Law 9.610/98 Art. 49, 50) | A simple or advanced e-signature works if the contract accepts the method. ICP-Brasil gives the strongest presumption (MP 2.200-2 Art. 10) | The object, each mode of use, and time, place and price for exercising the right (Art. 49(VI), 50 §2) | No written term means 5 years at most, no territory the signing country, and only existing modes of use pass (Art. 49) |
| Chile | Public instrument or notarized private instrument, recorded in the Intellectual Property Registry within 60 days (Law 17.336 Art. 73) | Notarial authorization given electronically with an accredited advanced e-signature, or on paper. A click alone does not count (Law 19.799 Art. 3-4) | No statutory list. Recording identifies the parties, the notary or official, the date and what is transferred (registry regulations) | Only commissioned software is deemed assigned, so contractors own other works, such as labels and text, unless assigned (Art. 8) |
| Colombia | Written as a condition of validity, and recorded in the national copyright registry to bind third parties (Law 23/1982 Art. 183) | A reliable simple e-signature can satisfy the signature rule, and a certified firma digital is stronger (Law 527/1999 Art. 7, 28) | The modes of exploitation, time and territory, since the transfer is limited to what the contract sets (Art. 183) | No stated time means 5 years, no territory the country of transfer, and blanket future-works transfers are non-existent (Art. 183) |
| Mexico | Always written, or the transfer is null, and every transfer is paid and temporary (Federal Copyright Law Art. 30) | A simple, attributable e-signature is legally sufficient, and an advanced one such as SAT e.firma is stronger (Commercial Code Art. 93, 97) | A proportional share of revenue or a fixed fee, which can’t be waived, and the duration (Art. 31, 33) | With no stated term a transfer lasts 5 years, and it may exceed 15 years only exceptionally, except software (Art. 33, 103) |
| Peru | Written, and each mode of use must be assigned expressly and in writing (Legislative Decree 822 Art. 89, 95) | A simple e-signature is legally valid, and a certified firma digital is stronger evidence (Law 27269 Art. 1, 3) | The rights, time, territory and each mode of use, plus a revenue share unless a lump sum is allowed (Art. 89, 92-93) | Rights not explicitly assigned stay with the author, and no stated territory means the country of grant (Art. 89) |
| Venezuela | Evidenced in writing, except for audiovisual, broadcast, software and employment works (Copyright Law 1993 Art. 53) | An e-signature meeting the security conditions equals a handwritten one, and parties may agree a simple method (Decree-Law 1.204 Art. 16) | Each form of exploitation and its remuneration, unless the assignment is expressly free (Art. 51) | Only forms of exploitation expressly stated pass, and future-works assignments must be specified and last at most 5 years (Art. 51-52) |
Sources:Ley 11.723 (InfoLEG, updated text), Arts. 4, 51-53Ley 25.506 Firma Digital (InfoLEG, updated text), Arts. 2, 3, 5, 6Código Civil y Comercial (InfoLEG), Arts. 286-288, 1618Lei 9.610/1998 (Câmara dos Deputados, updated text), Arts. 4, 27, 49-51Lei 9.609/1998 software law (Câmara), Art. 4MP 2.200-2/2001 (Câmara), Art. 10Lei 14.063/2020 (Câmara), Arts. 1, 2, 4Ley 17.336 Propiedad Intelectual (BCN LeyChile), Arts. 8, 16, 73Ley 19.799 documentos y firma electrónica (BCN LeyChile), Arts. 2-5Ley 23/1982 (Función Pública), Arts. 20, 30, 182, 183Ley 1450/2011 (Función Pública), Arts. 28 and 30 amending Ley 23/1982 Arts. 20 and 183Ley Federal del Derecho de Autor (Cámara de Diputados, last reform DOF 14-05-2026), Arts. 19, 30-34, 83-84, 103Código de Comercio (Cámara de Diputados), Arts. 89, 93, 97Código Civil Federal (Cámara de Diputados), Arts. 1834, 1834 bisDecreto Legislativo 822 (gob.pe PDF), Arts. 16, 21, 71, 88-95Ley 27269 Firmas y Certificados Digitales (gob.pe PDF), Arts. 1-3Ley sobre el Derecho de Autor 1993, WIPO Lex (Spanish/English), Arts. 5, 50-53, 59
United States and Canada
An assignment needs a signed writing, electronic signatures are valid, and work made for hire covers contractors only in narrow cases.
| Country | The transfer must be | Electronic signature that works | The agreement must state | Watch out for |
|---|---|---|---|---|
| Canada | Written and signed by the contractor, or the assignment is not valid (Copyright Act s.13(4)) | A robust e-signature with ID checks and an audit trail is likely enough, though no federal law confirms it (PIPEDA s.43) | None prescribed, but add an express moral rights waiver, since an assignment alone does not waive them (s.14.1(3)) | Rights revert to the author’s estate 25 years after the author’s death, despite any agreement, except for collective works (s.14) |
| United States | Written and signed by the contractor, or the transfer is not valid. Notarization is optional (17 USC 204(a)-(b)) | A standard click or typed DocuSign-style signature satisfies the signed-writing rule (E-SIGN Act, 15 USC 7001(a)) | None prescribed, but the writing must show an intent to transfer copyright | Assignments, unlike works made for hire, can be terminated in a 5-year window starting 35 years after the grant (17 USC 203) |
Electronic signatures in the EU: simple, advanced and qualified
The EU’s eIDAS Regulation recognizes three levels of electronic signature. Article 25 says no signature may be denied legal effect just because it is electronic, but only a qualified electronic signature has the equivalent legal effect of a handwritten signature in every member state. So where national law requires written form for a copyright transfer, a simple or advanced signature may not satisfy it.
A qualified electronic signature is created with a qualified signature device and a qualified certificate from a trust service provider on the EU trusted list. Major e-signature platforms offer it as an add-on with identity verification.
What a contributor IP assignment for AI data should include
Whatever the country, an assignment for training data should leave no use unnamed. Courts in several countries read transfers narrowly, so anything not listed may stay with the contributor.
- The deliverables: labels, annotations, rankings, written answers, prompts, code and recordings, and any material the contributor brings in.
- Every use, named one by one: reproduction, modification, translation, distribution, use to train, evaluate and fine-tune AI models, and sublicensing to your customers.
- Duration and territory: worldwide and for the full term of copyright where the law allows, stated expressly.
- Remuneration: the per-task rate or fee that covers the transfer, where the law presumes the transfer is paid.
- Moral rights: a waiver or an agreement not to assert them, where the law allows it.
- The signature the contributor’s country requires, and a record of the agreement version, signature evidence and the tasks it covers.
How Toku handles IP transfers for contributor pools
Toku Contributor Payouts contracts each contributor as contractor or agent of record, drafts the IP transfer for their country, collects the signature that country requires (including a qualified electronic signature where written form is mandatory) and keeps the agreement, signature evidence, tasks and payouts together as a chain-of-title record you can hand to a customer’s vendor review.
None of the contractor of record providers we compared in November 2026 documents qualified electronic signatures for contractor IP transfers. Deel, for example, describes its e-signatures as simple electronic signatures.
General information for teams planning contributor programs. Classification, tax, payment eligibility, and data obligations depend on the actual arrangement and applicable local requirements.