The Centre submitted comments on the Working Paper on Generative AI and Copyright (Part 1), prepared by a committee constituted by the Department for Promotion of Industry and Internal Trade (DPIIT). The Working Paper proposes major amendments to India’s copyright law that would effectively grant a retroactive, blanket statutory licence to AI developers to use lawfully accessed copyrighted works for AI training, subject to the payment of a revenue-based fixed royalty to a centralised collecting body known as the Copyright Royalties Collective for AI Training (CRCAT). While acknowledging the Working Paper’s novel and well-intentioned approach, the Centre’s comments identified three principal concerns: first, that the proposed royalty collection and distribution mechanisms are impractical; second, that they are misaligned with the objective of balancing rightsholders’ interests with the need to ensure access to high-quality training data; and third, that they risk unintended negative consequences, including more rightsholders placing works behind paywalls and AI developers choosing to avoid Indian territory or Indian works. The Centre also noted that the Working Paper presumes infringement under existing law, a question that remains unsettled before Indian courts.