Patents, Designs & Copyright
Posted on 20/11/2025

Changes being reviewed at the UKIPO design consultation

What are the key areas of reform and why do these proposals matter?

Background

The UK design sector is valued at £100 billion and plays a role in driving innovation and competitiveness. Design rights form the legal foundation that enables individual and businesses to protect their creative output and maintain a fair marketplace.

To ensure the system remains fit for purpose, the UK Government launched a consultation on September 4th, 2025, seeking input from the design community on proposed reforms aimed at strengthening and simplifying the UK’s design protection regime.

Key Areas of Reform

The main areas of focus for the consultation includes:

1. Reintroduction of Search and Examination

For nearly 20 years the UK, in line with Europe, has not conducted substantive searches on design applications. The Government is now considering reintroducing a system of search and examination prior to enforcement, a practice already in place in many jurisdictions.

Under the proposals, the UK Intellectual Property Office (UKIPO) could be granted greater powers to examine and reject designs that lack novelty or are filed in bath faith. Three options are under review:

  • Option 1 – No change
  • Option 2 – Allow the registrar to conduct a search
  • Option 3 – Introduce a two-stage system requiring full search and examination before enforcement

2. Deferment

Immediate publication of a design upon registration can create commercial challenges for businesses with long production development cycles. While UK applicants can currently delay registration and publication for up to 12 months, there is no explicit statutory provision for deferment.

The government is proposing changes to formalise and extend this process. Under the current system deferment can be up to 12 months from the filing date. The proposed reforms discuss how long the deferment period should be, and at which point deferment should commence from. Key options under consideration include:

Length of deferment:

  • Option 1 – Length of deferments of 12 months
  • Option 2 – Length of deferment of 18 months
  • Option 3 – Length of deferment of 30 months

Commencement of deferment:

  • Option 1 – From the date of filing
  • Option 2 – From the priority date of the application

3. Overlapping Design Rights

The UK currently operates under a complex patchwork of overlapping protections, including:

  • UK registered designs
  • UK unregistered design rights (design right)
  • International registered designs
  • Supplementary unregistered designs (SUD)
  • Copyright

Each of these rights varies in scope, duration, and commencement, making the system challenging to navigate and complicating efforts to determine what a designer has protected. To simplify this framework, the government is considering the following options:

  • Option 1 – No change
  • Option 2 – Retain SUD, abolish design right
  • Option 3 – Consolidate the unregistered design framework
  • Option 4 – Make no changes to the copyright system
  • Option 5 – Amend copyright legislation
  • Option 6 – Update copyright exceptions framework

4. Addressing Post-Brexit Challenges

Since Brexit, a design first disclosed in the UK qualifies for protection as a SUD, while a design first disclosed in the EU is protected as an unregistered community design. Unlike the pre-Brexit system, a single disclosure no longer provides the same protection in both territories. This new system has introduced additional complexity for businesses, especially those operating across the UK and EU. To address these challenges, the consultation is exploring several options, including:

  • Option 1 – No change
  • Option 2 – Unilaterally recognise simultaneous disclosure law
  • Option 3 – Introduce a grace period for unregistered designs
  • Option 4 – SUD is created following first disclosure anywhere in the EU
  • Option 5 – SUD is created following first disclosure anywhere in the world

5. Improving Enforcement and Access to Justice

A proposed small claims track within the Intellectual Property Enterprise Court (IPEC), specifically for design disputes, could make it easier and more affordable for small businesses to enforce their design rights.

6. Modernising for the digital age:

The consultation explores how the UK design system can better accommodate technological advancements, particularly in relation to digital design formats and artificial intelligence. The UK proposals include providing further guidance on what can be protected as a design and amending legislation to clarify what is eligible subject matter.

Design Filing Formats

To reflect the increasing use of digital tools in design, the Government is exploring options to expand the formats accepted for design registration. These options are not intended to be mutually exclusive and could be implemented in combination:

  • Option 1 – Allow users to file moving or animated designs using alternative file formats (e.g. video clips, CAD files)
  • Option 2 – Permit applicants to include additional descriptions alongside still images or video clips

AI-Generated Designs

The consultation also addresses the growing role of artificial intelligence in the creative process and whether designs generated without human authorship should be eligible for protection:

  • Option 1 – Maintain the existing protection for computer-generated designs without a human author
  • Option 2 – Reform the current protection framework for such designs
  • Option 3 – Remove existing protection for computer-generated designs without a human author
  • Option 4 – Introduce a requirement to collect data on whether AI was used in the creation of a registered design

Why this matters

Whether you are a designer or a brand owner these proposed reforms could significantly impact how you protect and enforce your design rights in the UK. For example:

  • Designers and businesses may benefit from stronger safeguards against abuses of the system and clearer rules around disclosure and registration.
  • Legal professionals will need to adapt to potential changes in enforcement procedures, copyright overlap, and AI-related design protection.
  • Startups and SMEs could gain easier access to justice through the proposed small claims track, making it more feasible to defend their creative assets.

Stakeholders should assess how the proposed changes may affect their current and future design strategies, particularly in relation to disclosure, enforcement, and the use of emerging technologies. Wilson Gunn is actively advising major design clients on their responses to the consultation and contributing to the response of The Chartered Institute of Patent Attorneys (CIPA).

Next steps

The consultation closes on November 27th, 2025. Feedback received will inform future policy decisions, with the aim of modernising UK design law and reinforcing the UK’s position as a global leader in design innovation.

Wilson Gunn would be happy to provide advice on how these changes could affect your design rights. If you would like to seek advice, please contact our team.

Wilson Gunn