On March 30, 2026, the Geneva Centre on Knowledge Governance partnered with the International Federation of Library Associations and Institutions (IFLA) and Electronic Information for Libraries (EIFL) to submit joint comments on Zambia’s Copyright and Related Rights Bill, 2025. Addressed to the Patents and Companies Registration Agency (PACRA), our submission champions fair and affordable access to knowledge for education, research, and socio-economic development. We recognize that the Bill contains several positive provisions from a public interest perspective, and our joint comments aim to ensure the new law properly supports libraries, researchers, and creators in Zambia.
For the full document, see the PDF below.
A significant portion of our submission responds to observations made by the International Federation of Reproduction Rights Organizations (IFRRO) and the International Confederation of Societies of Authors and Composers (CISAC). We firmly pushed back against their restrictive policy preferences, which they incorrectly claimed were mandated by international treaties. Specifically, we defended PACRA’s policy decisions to permit private copying without mandatory remuneration, supported educational copying exceptions, and strongly opposed the elimination of the Bill’s highly beneficial proposed exception for non-commercial text and data mining (TDM). We also argued against introducing a public lending right, which would operate as a detrimental tax on reading and education in a developing country context.
Finally, our submission offers several constructive recommendations to future-proof Zambia’s copyright framework and enhance access to knowledge. We urge PACRA to adopt an open, flexible “fair dealing” provision and to expand the TDM exception to further support local research and innovation in fields like agriculture and healthcare. Furthermore, we recommend clarifying the rules around library lending and the exhaustion of rights, protecting statutory copyright exceptions from being overridden by restrictive digital licensing contracts, and adding the necessary provisions to allow the cross-border exchange of accessible format copies under the Marrakesh Treaty for persons with print disabilities. To protect local creators from unequal bargaining power, we also suggest giving authors the unwaivable right to terminate copyright assignments after a set number of years.
The full PDF of our comments as submitted can be viewed, downloaded and printed below.
