Field guide · Part 12 of 13
International Differences
3 rules on international differences for architectural and real estate photographers, each with its source.
Educational, not legal advice. Every rule below carries its source and a
confidence level, because some of this is settled law and some is contested. The ones marked
contested need a lawyer's judgement on your facts, not a rule of thumb.
Rule 49Surprising
The US, UK, Germany, and Belgium let you publish building photos freely; France and Italy restrict commercial use.
This “freedom of panorama” gap means a shot legal to license in the US may be restricted for commercial use in parts of the EU.
The misconception: “If it’s legal here it’s legal everywhere.”
Source: US 17 U.S.C. 120(a); UK Copyright, Designs and Patents Act 1988 section 62; Belgium introduced a freedom of panorama exception by the Act of 27 June 2016, which is why the Atomium is now the standard example of a restriction that ENDED rather than one that applies. France’s 2016 reform covers non-commercial use by individuals only, so commercial images of copyrighted French architecture may still need authorization. Confirm the current position in any country you licence into: several changed in 2016 and the older guidance still circulating is out of date.
Confidence: High. Country-specific; verify per jurisdiction.
Rule 50
The Eiffel Tower is free to shoot by day but restricted when its night lighting is on.
The daytime structure is public domain, but the illumination display is separately copyrighted, a vivid example of how EU rules differ from US ones.
The misconception: “Famous landmarks are always free to license.”
Source: French copyright treatment of the tower’s light show; widely reported freedom-of-panorama example.
Confidence: Medium-high. Jurisdiction-specific.
Rule 51
Most of the world grants stronger, non-waivable moral rights than the US.
In many civil-law countries authors keep attribution and integrity rights even after selling the work and sometimes cannot waive them, unlike the narrow, waivable US VARA regime.
The misconception: “Moral rights are the same everywhere.”
Source: Berne Convention Article 6bis; comparative moral-rights literature.
Confidence: High. Country-specific.
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Resid
Every rule here is a decision Resid makes for you.
It finds the companies who worked on a property, prices each licence on real licensing data,
writes the agreement, and collects.
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