Abstract In copyright law, moral rights of authorship are distinct from economic rights in economic works, breaking down into four basic rights, those of attribution, integrity, disclosure and withdrawal. Whilst economic rights are transferable, moral rights are not. The article explores current and historical moral rights in the GCC region, specifically UAE, Saudi Arabia, Kuwait, comparing the Sharia and civil code of these nations, to English and American Common Law and European Civil codes, addressing how culture and history has impacted the need or style of protection of moral rights. The article recommends reforms to GCC codes to permit stronger enforcement and pre‐empt future demand for copyright protections from international investors, considering the economic changes and the rise of AI used in creative works .
Almajed et al. (2026) studied this question.