A window in two stages — the Copyright Office opens its tenth triennial proceeding
On 9 June 2026 the United States Copyright Office began the tenth triennial rulemaking under the Digital Millennium Copyright Act. Petitions for exemptions were due 24 August and comments on renewal petitions 28 September, two deadlines in one proceeding.
Document overview (primary data)
- Document typeProposed rule
- AgencyLibrary of Congress
- Citation91 FR 34795
Key points
- The United States Copyright Office opened the tenth triennial rulemaking proceeding under the Digital Millennium Copyright Act.
- The proceeding determines whether to recommend temporary exemptions to the prohibition on circumventing access controls on copyrighted works.
- Petitions of either kind were due by 11:59 in the evening, Eastern time, on 24 August 2026, seventy-six days after publication.
- Comments answering the renewal petitions were due by the same hour on 28 September 2026, a hundred and eleven days after publication.
- The docket is 2026-4 and the document runs to four pages, carrying two deadlines in a two-stage structure.
1A deadline need not be single
The seven documents so far each carried one deadline. This one carries two. Petitions for exemptions were due 24 August; comments on those petitions, 28 September. Counted from publication, that is seventy-six days and a hundred and eleven.
2The window in two stages
- 19 June 2026The proceeding is opened by this notice, four pages
- 224 August 2026, 11:59 p.m. EasternPetitions for new exemptions and for renewal of current ones are due, seventy-six days
- 3ThenThe renewal petitions received become public and the stage for responding to them begins
- 428 September 2026, 11:59 p.m. EasternComments in response to renewal petitions are due, a hundred and eleven days
The first stage gathers what is to be argued; the second gathers what people think of it. One proceeding holds two roles, proposal and consideration. From a commenter's side, missing the first stage still leaves room to speak in the second.
3Repeated every three years
This is the tenth such proceeding. The Act prohibits circumventing access controls as a general matter, then provides for a review every three years to grant temporary exemptions for certain uses. Exemptions are not permanent: when they lapse, renewal has to be petitioned for.
A proceeding that is set to recur settles into a standard shape, windows included. By the tenth round, those petitioning and those responding both know when to do what. The hundred and eleven days are part of that established form.
4A long window can be a sum of stages
A hundred and eleven days is among the longest here, but it breaks into seventy-six plus thirty-five. It is not one continuous period of consideration but two of different character, laid end to end. The final article closes the series with a hundred and fourteen days given to a decision about a single local bridge. The original is in the Federal Register.
Why it matters
A comment window need not be single. Separating the stage that collects proposals from the stage that collects responses to them produces two deadlines and a longer total as a matter of course. The hundred and eleven days here break into seventy-six and thirty-five, two periods of different character rather than one stretch of consideration, and in a proceeding set to recur that staging is carried forward as established form.
FAQ
Why are there two deadlines?
What is the triennial rulemaking?
Does an exemption continue once granted?
Sources (primary)
Source: Federal Register (federal documents, public domain). Links go to the official site.