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Copyright and Risks of AI-Generated Code: OSS Licenses, Copyleft, and Enterprise Best Practices

About 5 minutes

Target audience: Developers and engineers using generative AI for code generation in business, corporate legal and IP staff, and team leads involved in OSS usage

As AI-assisted coding (GitHub Copilot, Amazon Q Developer, and others) becomes widespread, enterprises need to understand the legal risks spanning copyright law, OSS licenses, and patent law before adopting these tools [1][2][3]. This article organizes the risks specific to AI-generated code and the measures enterprises should take.

Under Japanese copyright law, a work is defined as “a creative expression of thoughts or feelings,” and human creative authorship is a prerequisite [1]. Code autonomously generated by AI without any human creative contribution is generally considered unlikely to qualify for copyright protection.

In practice, however, it is rare for AI to generate code with complete autonomy. Humans participate in the creative process in the following ways:

  • Designing and iteratively refining prompts
  • Selecting the best option from multiple generated candidates
  • Modifying, refactoring, and combining generated code

The prevailing interpretation is that the portions reflecting human judgment, editing, and creative selection may give rise to copyright [1].

PartyNature of Rights
AI tool vendorOutput use conditions, indemnity, training-data use, and log handling depend on the service’s terms and administrative controls [2][3]
User (individual or enterprise)Portions with human creative contribution may be protectable, while autonomously generated AI portions have a limited protection scope [1]
Copyright holders of training dataMay have grounds to assert rights if generated code is derived from or substantially similar to the training data [1]

Tool-selection premise: Services such as GitHub Copilot and Amazon Q Developer differ in features, administrative controls, and treatment of output [2][3]. Rights, indemnity, code referencing or duplicate detection, and handling of input data must be checked against the official documentation and contract terms in effect at adoption time.

OSS License Issues: Open-Source Code as Training Data

Section titled “OSS License Issues: Open-Source Code as Training Data”

When using generative AI coding tools that may learn from or reference public code, teams need to verify which license conditions may affect inputs, outputs, and candidate code. Public repositories include code under permissive licenses such as MIT and Apache 2.0, but also code under copyleft licenses such as GPL, LGPL, and AGPL [4].

Training Data
├── MIT-licensed code (permissive: free to reuse and use commercially)
├── Apache 2.0-licensed code (permissive: includes patent clause)
├── GPL code (copyleft: same license propagates to derivatives)
├── LGPL code (weak copyleft: conditions relaxed for dynamic linking)
└── AGPL code (strong copyleft: also applies to network-served software)

The core condition of the GPL license is that when software incorporating GPL code is distributed, the corresponding source code must be made available under GPL conditions [4].

Risk scenario with AI-generated code:

  1. AI outputs code substantially similar to GPL code
  2. A developer incorporates that code into a proprietary product
  3. The GPL conditions “propagate,” potentially requiring release of the entire product’s source code

This “copyleft contamination” is a risk that directly impacts enterprise intellectual property strategy [4].

Copyright infringement requires both access (provenance) and substantial similarity, and for code, similarity is evaluated on these dimensions:

  • Literal similarity: Code copied verbatim or near-verbatim
  • Non-literal similarity: Similarity in code structure, algorithms, or program flow

Note that ideas and algorithms themselves are not protected by copyright (the idea-expression dichotomy). Code that independently implements the same algorithm with a different expression does not constitute copyright infringement [1].

Patent Rights: Implementation Risk of Algorithms

Section titled “Patent Rights: Implementation Risk of Algorithms”

Separately from copyright, code generated by AI may infringe existing patents covering the technology or process it implements [5].

  • Even if AI-generated, code that practices a patented invention constitutes patent infringement [5]
  • Whether the generation process was automated does not affect the patent infringement determination
  • Patent investigation (Freedom to Operate analysis) is required separately from copyright checks

Patent investigation of generated code is especially important in high-patent-density fields such as healthcare, finance, telecommunications, and security.

AI-generated code can also contain security issues.

Research published in 2021 found that code generated by GitHub Copilot can contain security vulnerabilities [6].

Risk TypeExample
Use of outdated or vulnerable APIsDeprecated cryptographic methods, deprecated functions
SQL injectionImproper query construction
Authentication weaknessesMissing permission checks, incomplete input validation
Sensitive information leakageHardcoded credentials or secrets
OS command injectionCommand execution involving external input

Generative AI produces code that “looks right,” but does not guarantee security correctness [6].

Item to VerifyReason
Training-data and referenced-code license policyAssess copyleft contamination risk [2][3][4]
Rights assignment and output use conditionsConfirm the scope in which the enterprise can use the code [2][3]
Availability of copyright indemnification programsConfirm the protection scope if infringement claims arise [2][3]
Enterprise-grade optionsManage input data, logs, access control, and code-reference detection [2][3]
Enterprise Code Generation Policy (Example)

1. Permitted Tools
   - Use only approved generative AI tools
   - Inputting code with personal accounts is prohibited (prevent leakage of sensitive code)

2. Mandatory Code Review
   - All generated code must go through human code review
   - Code critical to security (authentication, encryption, etc.) requires expert review

3. OSS Compliance
   - Scan generated code with an OSS scanning tool before committing
   - When copyleft licenses are detected, consult legal or IP departments

4. Prompt Management
   - Do not include sensitive information, customer data, or internal system details in prompts
   - Maintain a record of the correspondence between prompts used and generated code

Tools used to detect license contamination in generated code:

  • FOSSA / Black Duck / Snyk — commercial OSS compliance tools
  • ScanCode / FOSSology — open-source scanning tools
  • Code reference or duplicate-detection features provided by AI tool vendors, such as GitHub Copilot code referencing [2]

Maintaining the following information about generated code can assist in responding when issues arise later.

Information to Record
- Name and version of the AI tool used
- Overview of the prompt used for generation
- Date and time of generation
- Code reviewer and review date
- OSS scan results and actions taken

Legal risks in AI-generated code extend beyond copyright to OSS licenses, patents, and security.

RiskDescriptionPrimary Response
CopyrightAmbiguity in rights ownership; similarity derived from training dataVerify terms of service; verify indemnification programs
Copyleft contaminationRisk of GPL and similar licenses propagating to the entire enterprise productOSS scanning; copyleft isolation policy
Patent rightsRisk that generated code infringes existing patentsFTO analysis; caution in high-patent-density areas
SecurityAutomatic generation of vulnerable codeMandatory code review; security scanning

Generative AI can dramatically improve development productivity, but recognizing these risks and designing governance around them is a prerequisite for sustainable enterprise adoption.

  1. e-Gov Law Search, Copyright Act (Act No. 48 of 1970)
  2. GitHub Docs, GitHub Copilot features
  3. AWS, Amazon Q Developer
  4. GNU Project, GNU General Public License version 3
  5. e-Gov Law Search, Patent Act (Act No. 121 of 1959)
  6. Pearce et al., Asleep at the Keyboard? Assessing the Security of GitHub Copilot’s Code Contributions, arXiv:2108.09293 (2021)
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