Copyright Office seeks comment on DMCA exemptions for smart TVs, home cameras and unsupported devices

The US Copyright Office has opened public comment on proposals that would give owners of smart TVs, home cameras and other connected devices more room to modify the software inside them. In a notice published in the Federal Register on October 28, 2026, the Office said the Register of Copyrights intends to recommend renewing all but one of the exemptions now in force under section 1201 of the Digital Millennium Copyright Act (DMCA), and it started three rounds of comment on requests for new or wider ones.

How the exemptions work

Under section 1201, getting around a technological measure that controls access to a copyrighted work is generally unlawful, and the exemptions for home devices are written for the computer programs inside them. Every three years, the Librarian of Congress can adopt temporary exemptions for specific noninfringing uses, on the Register's recommendation. The current set took effect on October 28, 2024, for three years. This cycle, the Office received 43 renewal petitions and 25 petitions for new or expanded exemptions.

What the Office plans to recommend renewing

Today's rules allow circumvention so that smart TVs, including separate streaming devices, and voice assistant devices can run lawfully obtained apps. Of the two, only the voice assistant exemption also covers removing software. A separate exemption covers diagnosis, maintenance and repair of devices designed mainly for consumers; in its renewal petition, iFixit said diagnosing or repairing an appliance can mean getting into a restricted service mode to read its fault codes. Nobody opposed renewing these, and the Office concluded that the conditions behind them are likely to continue.

According to the Office's rulemaking page, renewed exemptions would stay in force from October 2027 to October 2030. The one exception is medical device repair, which met what the Office called meaningful opposition and will be reconsidered as a new proposal.

What is newly proposed

The Office asked whether the devices named in the advertising proposal have enough in common, in their software, access controls and effects on users, to support a single exemption. It also noted that, outside vehicle repair, the Register has consistently declined to recommend extending repair exemptions to modifying device software, and it asked commenters to explain whether such modification would be noninfringing.

Our guide to smart TV viewing data explains what automatic content recognition collects and which TV settings turn it off.

What it does not change

For now, the exemptions adopted in 2024 still apply, and nothing proposed in this notice is in force. The rulemaking covers only the act of circumvention: the statute gives no authority to exempt the separate anti-trafficking provisions, which bar trafficking in circumvention technologies, products, devices and services, and the Office says only Congress can expressly exempt activities that might count as trafficking.

How to comment

• December 7, 2026: comments from supporters, and from anyone sharing relevant information without taking a side.
• February 22, 2027: comments from opponents.
• March 22, 2027: replies from supporters and neutral commenters.

Comments are filed through Regulations.gov, with a separate submission for each class. Short comments are limited to 5,000 characters, and longer ones to 25 pages per class for each submitter, according to the Copyright Office's 2027 rulemaking page.