Tenth Triennial Section 1201 Proceeding, 2027 Cycle

Comment submission

The Copyright Office has initiated the tenth triennial rulemaking proceeding under the Digital Millennium Copyright Act (DMCA), section 1201 of Title 17. Under this provision, the Librarian of Congress, upon the recommendation of the Register of Copyrights, may adopt temporary exemptions to section 1201’s prohibition against circumvention of technological measures that control access to copyright-protected works.


The triennial rulemaking identifies classes of works for which the DMCA’s anti-circumvention provision adversely affects, or is likely to adversely affect, in the next three years, users’ ability to make noninfringing uses. The Librarian then issues a regulation exempting the classes from the prohibition for the following three-year period.


The Office uses a streamlined procedure to renew exemptions granted during the ninth triennial rulemaking. Renewed exemptions remain in force for an additional three-year period (October 2027–October 2030).


Petitions for renewal of current exemptions and petitions proposing new exemptions were due August 24, 2026. Written comments in response to petitions for renewal were due September 28, 2026.


On October 28, 2026, the Office issued a notice of proposed rulemaking, stating that it has reviewed all forty-three renewal petitions and related comments and that the Register intends to recommend readoption of all but one existing exemption.1 Because opponents of the exemption regarding medical device repair stated meaningful opposition to its renewal, the Office will consider it as a new petition and elicit further submissions and evidence in the normal rulemaking proceeding.


The Office has also evaluated the petitions for new or expanded exemptions and grouped them into ten classes, including the meaningfully opposed renewal petition. It is now initiating three rounds of public comment on those classes:


  1. December 7, 2026: First round comments are due. Legal and evidentiary submissions from those who support new or expanded exemptions are due. Those who neither support nor oppose an exemption but seek to share pertinent information may also comment.

  2. February 22, 2027: Opposition comments are due. Responsive legal and evidentiary submissions from those who oppose the adoption of a proposed exemption are due.

  3. March 22, 2027: Reply comments are due. Reply comments from supporters of a proposed exemption and those that neither support nor oppose a proposed exemption are due.

Commenters may submit comments for more than one class; however, commenters must submit a separate comment for each proposed class they wish to address.


Comments must be submitted electronically through Regulations.gov. Short-form comments are limited to 5,000 characters. Long-form comments may be up to twenty-five pages per class, per submitter (including joint submissions). For Proposed Class 8: Computer Programs—Repair only, comments on each subclass may total up to twenty-five pages. Commenters may also submit documentary and multimedia evidence, which is not included in the page limits. For information about how to submit comments and multimedia evidence, click the “Comment submission” button above.


Participants in the proceeding are encouraged to familiarize themselves with section 1201(a)(1) and the rulemaking requirements. For more information, commenters should carefully review the notice of proposed rulemaking and comment submission instructions. Additional resources are available on the Rulemaking Proceedings Under Section 1201 of Title 17 webpage.

1 On November 2, 2026, the Office issued a correction to the notice of proposed rulemaking that fixed a typographical error.