Determining the Copyright Holder for AI-Generated Content: Human Creator, AI System, or Platform?

The popularity of AIGC has raised legal challenges regarding copyright ownership. This article aims to explore whether copyright should belong to human users, AI systems, or development platforms. The core issue of AIGC lies in the fact that its output lacks the "independent intent" and "creativity" required by copyright law. In response to this, international responses vary: the United States adheres to the "human author" principle, the European Union is exploring new frameworks, while China tends to position AI as an auxiliary tool. This article holds that copyright should belong to human creators because they play a decisive and leading role throughout the entire creative process. In essence, AI systems are advanced tools that cannot be independently created and do not have legal subject status. The role of the platform should be that of a manager responsible for content review, risk prevention, and control. To promote the adaptation of laws to technological development, this article suggests that legislation should clearly define the dominant position of human creators and increase the compliance responsibilities of platform providers. At the same time, it should retain a certain degree of flexibility and explore the possibility of recognizing certain rights enjoyed by developers or platforms in specific circumstances, in order to balance the rights and interests of creators with technological innovation.