UMG told the Copyright Office AI training needs a license

The system

Before Universal Music Group struck licensed AI deals with Udio and ElevenLabs, it put its position on the public record. UMG's General Counsel Jeffrey Harleston and Head of Litigation Alasdair McMullan filed Comments of Universal Music Group with the U.S. Copyright Office on 30 October 2023, responding to the Office's notice of inquiry on artificial intelligence and copyright, a public filing posted to the government's own comment docket rather than a marketing statement.

What the documents establish

UMG's filing states 'there are two fundamental principles that must be maintained': first, that copyright protection 'can and should only extend to expressive content created by human beings,' with technology allowed to assist but not replace human authorship; second, that 'use of copyrighted content by AI, whether for training or other purposes, requires permission from the copyright owners, via negotiated licenses.' The filing extends this to voice and likeness, stating that UMG's artists 'own rights of publicity in their names, likenesses, voices' and that AI voice-cloning without consent violates those rights independent of copyright. UMG's reply comments, filed 6 December 2023, restate both principles 'as noted in our initial submission,' showing the position held across the full comment period rather than shifting under pressure. Two years later, UMG's own announcement of its Udio settlement and license, dated 29 October 2025, describes a platform 'trained on authorized and licensed music,' consistent with the licensing principle UMG had filed two years earlier.

Craft and rights

For working musicians signed to or distributed through UMG labels, this filing is the company's stated floor: no training without a negotiated license, and no use of an artist's voice or likeness without that artist's consent, as UMG frames it. What the filing does not do is create any enforceable right beyond what copyright and publicity law already provide; it is UMG's advocacy position submitted to a policy process, not a court ruling or a binding third-party standard. This is an editorial point worth separating from UMG's own language: an artist's actual protection depends on their contract with UMG and on whichever law eventually results from proceedings like this one, not on the comment letter itself.

Outcomes and open questions

UMG has since converted the licensing principle into commercial deals, but the human-authorship principle remains a position in an unresolved policy debate the Copyright Office itself declined to settle with a blanket rule in its later Part 3 report.

• Does your own contract require your consent before your voice or likeness is used to train an AI model?
• Would a labelmate's licensed-AI deal, like UMG's with Udio, automatically cover your own catalogue?
• Has UMG's practice matched this filing's stated principles in cases you can check?

A major label's public comment letter is a useful benchmark for what responsible-AI claims should include, but it binds only the company that wrote it, and only as far as its own later contracts choose to honor it.