16.87 Copyright laws in some other jurisdictions recognise free-use and remunerated exceptions that apply to internet transmissions. As discussed above, the United States operates a statutory licensing scheme covering internet radio services.
16.88 In New Zealand, under the Copyright Act 1994 (NZ), a number of copyright exceptions, similar to the broadcast exceptions, refer to ‘communication’ or a ‘communications work’. This is defined as ‘a transmission of sounds, visual images, or other information, or a combination of any of these, for reception by members of the public, and includes a broadcast or a cable programme’. A communications work, unlike the concept of a broadcast in Australian copyright law, appears to apply to transmissions using the internet.
16.89 For example, the New Zealand Act provides an exception in relation to the incidental recording of works, sound recordings or films for purposes of communication. This is the equivalent of the reproduction for broadcasting provisions contained in ss 47, 70 and 107 of the Australian Act, but extends to facilitating internet transmission. The New Zealand Act also provides an exception in relation to the copying and communication of ‘communication works’ for educational purposes, an equivalent of the pt VA scheme under the Australian Act, but which extends to internet transmission more broadly.
16.90 However, some other exceptions in the New Zealand Act remain restricted in their application to broadcast and cable transmission. For example, the New Zealand Act provides an exception for the free public playing or showing of a broadcast or cable program, which does not extend to internet transmissions.
16.91 In the United Kingdom, under the Copyright, Designs and Patents Act 1988 (UK), copyright exceptions similar to those discussed in this chapter, still apply only to broadcasts—defined as including only ‘wireless telegraphy’—or ‘cable programmes’.
Copyright Act 1994 (NZ) s 2 definition of ‘communication work’, introduced by the Copyright (New Technologies) Amendment Act 2008 (NZ).
 Ibid s 85.
 Ibid s 48.
 Although it provides a free-use exception where voluntary licensing is not available, rather than for a statutory licensing scheme.
Copyright Act 1994 (NZ) s 87.
Copyright, Designs and Patents Act 1988 (UK) s 6. See, eg, Copyright, Designs and Patents Act 1988 (UK) s 31 (Incidental inclusion of copyright material); s 32 (Things done for purposes of instruction or examination); s 34 (Performing, playing or showing work in course of activities of educational establishment).