Rethinking industrial relations: Policy ecologies,cultural work and artificial intelligence

Abstract

This article explores how, in reshaping creative labour in Australia's cultural and creative industries, artificial intelligence is exposing the limitations of the current industrial relations framework. Using a policy ecology lens and drawing on submissions from creative industries stakeholder groups to two parliamentary inquiries, the article maps the fragmented governance of creative labour across industrial relations, copyright law, cultural policy. As artificial intelligence is disrupting attribution, income, and authorship in the cultural and creative industries, many freelance and contract-based workers fall outside the core workplace protections afforded to employees. The article argues that a reimagining of industrial relations is required to ensure that creative labour is adequately protected in an economy increasingly driven by artificial intelligence.

Introduction

Workers in Australia's cultural and creative industries (CCIs) have long been impacted by the broader labour market transformations that define contemporary capitalism. Characterised by episodic, freelance, project-based work and portfolio careers, the sector exemplifies the rise of atypical forms of employment that increasingly define the contemporary economy. These work arrangements test the limits of Australia's industrial relations (IR) system, which remains structurally oriented towards the standard employment relationship.

Artificial intelligence (AI) is intensifying the structural vulnerabilities workers in the CCIs face and exposing the inability of Australia's IR system to respond to the realities of non-standard work. Generative AI (GenAI) technologies are increasingly used to automate scriptwriting, image creation, voice synthesis and likeness replication, and in the process are accelerating the erosion of attribution, consent and income security for creative workers. These developments are not occurring in a regulatory vacuum; rather, they are colliding with a system that is not designed to effectively protect the creative industries workforce.

The Australian Government’s 2023 cultural policy, Revive: a place for every story, a story for every place, explicitly recognises artists as workers and commits to advancing fair remuneration, sustainable careers and inclusive industry standards as central to sectoral development (Australian Government, 2023). Yet this recognition has not been matched by institutional reform. The regulatory infrastructure governing creative work remains fragmented and outdated, unable to accommodate the realities of freelance and contract-based labour, let alone the disruptions introduced by AI.

This paper undertakes a policy ecology analysis of the CCIs to trace how IR, cultural policy, copyright law and technology governance interact to structure the conditions of creative labour. Rather than treating these domains as discrete, our policy ecology analysis will demonstrate how the CCIs are increasingly shaped by overlapping, fragmented and often incoherent policy domains and how their entanglements produce regulatory exclusions and institutional gaps that undermine fair work. In so doing, the article calls for a rethinking of IR as a multi-sited, cross-sectoral field of governance that must be responsive to the realities of contemporary labour market transformations.

The article proceeds in four sections. Section ‘Cultural work and workers’ provides a brief literature review of work and employment in the Australian CCIs to establish a baseline for understanding the complexity of precarity that characterises creative labour. This empirical grounding provides critical context for analysing how copyright law functions as a parallel and intersecting regulatory regime to IR, shaping the terms under which creative labour is contracted, valued and remunerated.

Section ‘AI concerns expressed in submissions’ examines the key themes across 30 submissions from creative industries’ stakeholder groups to the Senate Select Committee on Adopting Artificial Intelligence (2024) and The House of Representatives Inquiry into the Digital Transformation of Workplaces (Standing Committee on Employment, Education and Training, 2024). These submissions were made by unions, professional associations, industry bodies, public and private media corporations and advocacy groups representing creative and cultural workers. Section ‘What is to be done?’ briefly explores international developments in the United States and Canada that offer a window into collective bargaining as a key strategy for protecting creative workers’ rights in industries impacted by AI. In section ‘Conclusion: policy ecologies and disorganised governance’, we return to the concept of policy ecologies to argue for reform and propose a reconceptualisation of IR to acknowledge the fragmented regulation of cultural and creative labour.

Cultural work and workers

In January 2023, the Australian Government launched Revive, its first national cultural policy in a decade (Australian Government, 2023). Framed as a five-year roadmap for the renewal of Australia's arts, entertainment and cultural sectors, Revive is notable for its cultural ambition which, critically, recognises the centrality of the cultural workforce, and for foregrounding labour issues within cultural policy discourse. The policy is underpinned by ten guiding principles that are to collectively inform the activities and investments of the Australian Government in the CCIs over the five years to 2028. Among these are commitments that ‘artists and arts workers have career structures that are long-term and sustainable’, and that ‘creative talent is nurtured through fair remuneration, industry standards and safe and inclusive work cultures’ (Australian Government, 2023: 19). These statements are noteworthy for their positioning of the cultural workforce as a form of economic and industrial activity deserving of the same protections, standards and regulatory attention as other sectors of the workforce.

Research demonstrates the urgent need for policy and regulatory support to sustain workers in Australia's CCIs, where income insecurity, precarious employment and deteriorating working conditions remain defining features of the sector. The Creative Workforce Scoping Study report (Creative Australia and SaCSA, 2025) identifies low wages, long hours, unsustainable workloads, limited career progression, workforce exits and acute mid-career skills shortages as key threats to career longevity and sectoral sustainability. As the literature review shows, similar findings emerge across a wide body of academic literature, which highlights the persistence of precarity, structural inequities and the shifting of risk onto individual workers (Cannizzo et al., 2025; Hennekam and Bennett, 2017).

In the music industry, Cannizzo et al. (2025) show how career sustainability is shaped by disability, regionality, gender and care responsibilities, with interruptions to work and the COVID-19 pandemic further intensifying precarity. Wolifson et al. (2023) also emphasise the spatial dimensions of precarity during the COVID-19 pandemic, showing how housing insecurity, venue closures and the loss of informal creative spaces compounded the challenges facing Sydney-based workers. Their typology of career models illustrates how the erosion of stable employment pathways compels artists to internalise risk and self-manage fragmented trajectories. In their analysis of the games industry, Keogh and Abraham (2022) describe chronic precarity, gendered exclusion and structural barriers to unionisation, alongside a pervasive culture of self-exploitation. Subsequent research into game music work confirms that most composers and performers operate under freelance or contract arrangements, typically as part of broader portfolio careers (Keogh et al., 2023).

Comparable patterns are evident across the visual arts, where McQuilten et al. (2025) document widespread underemployment, reliance on unpaid labour and persistent gender pay inequities, despite high levels of education among workers. Employment is dominated by casual and fixed-term contracts, with career sustainability contingent on short-term grant funding and access to culturally safe workplaces. In the screen and live performance sectors, contract and freelance work also dominate, with Eltham's (2024) Crew Care report highlighting overwork, mental health distress and the absence of safe working hours.

Importantly, precarity is not evenly distributed. Structural inequalities related to gender, disability, race and caring responsibilities deepen the risks and impacts of insecure work for some cultural workers more than others. Coles et al. (2022) demonstrate that women cinematographers remain under-represented in leadership roles and are often channelled into less prestigious and lower-paid work contracts compared to men, despite equivalent training and experience. The Disability and Screen Work report (O’Meara et al., 2023) identifies exclusionary production models, inaccessible workplaces and inadequate accommodations, while McQuilten and MacNeill (2025) show that culturally and linguistically diverse visual artists face significant barriers to entry and career advancement. The Raising Their Voices report (MAPN Consulting, 2022) documents widespread sexual harm, harassment, bullying and systemic discrimination across the Australian music industry, with women, First Nations people, People of Colour, LGBTIQ +  individuals, and people with disability disproportionately affected. Precarity is produced not only through freelance and project-based work but also through entrenched gendered, racialised and ableist exclusions, which mutually reinforce one another to constrain sustainable careers. What remains striking is the absence of regulatory frameworks capable of addressing these structural inequities.

In its normative cultural policy ambitions, Revive has drawn sharp focus on the inadequacy of the IR system to confer basic rights and protections to the estimated 296,000 workers who in 2023 constituted Australia's cultural workforce (Australian Government, 2024: 7). In its 2024 analysis of the cultural and creative sector, the Bureau of Communications, Arts and Regional Research reports that of the 95,753 businesses in the CCIs, two-thirds (65.6%) are non-employing entities; in other words, they consist of sole traders, partnerships with no employees and the like (Australia Government, 2024: 22). The proportion increases in some sectors with non-employing businesses comprising 79% of total entities in the literature, creative and performing arts, and visual arts and crafts sectors. In short, the organisation of work and capital in the CCIs exemplifies the very forms of atypical, precarious and deregulated work and labour markets that have become central to IR debates in the post-Fordist era (Conor et al., 2015; Hesmondhalgh and Baker, 2015; Oakley, 2011). As Revive itself notes, ‘artists are the original gig workers’ (Australian Government, 2023: 53).

Only months after the release of Revive, members of both the Writers Guild of America (WGA), representing 11,500 screen writers, and the Screen Actors Guild—American Federation of Television and Radio Artists (SAG-AFTRA), with a membership of over 160,000 on- and off-screen actors, recording artists and media professionals, took strike action in response to the unregulated deployment of GenAI technologies. These included the use of AI in script development, image generation, voice synthesis and likeness replication, technologies which threaten not only to displace human creators but to bypass authorship and consent altogether (Burk, 2023). The Hollywood strikes foregrounded the centrality of creative workers in emerging struggles over automation, rights of attribution, residuals, and the fragmented, complex and tenuous legal regime under which they negotiate their working lives.

These struggles are not new, and technological disruption in the CCIs has many historical precedents, perhaps no more so than in the music industry. Kraft (1996) describes the ways that musicians in the US attempted to resist the impact of sound recording on their livelihoods; Leyshon (2014) analyses the impact of digitisation on the global music economy; and subsequently Leyshon and Watson (2025) examine shifting power relations in the music industries that digitisation has produced. The SAG-AFTRA strike is however emblematic of a broader reckoning across the CCIs and beyond where GenAI technologies are precipitating a structural transformation in the organisation, valuation and, we argue, regulation of creative labour.

As Nath (2025) argues, this transformation constitutes a ‘crisis of relevance’, wherein algorithmic systems automate writing, music composition, visual art and performance—tasks once considered uniquely human—and in the process destabilise both the economic foundations and cultural legitimacy of creative work. Allison (2024) warns that AI-driven technologies enable studios to create digital replicas of human actors that can perform indefinitely, bypassing issues such as ageing, contractual disputes and bodily autonomy. These technologies privilege older white male stars with extensive archival material, while marginalising women and racialised performers whose bodies and voices are less likely to be preserved or valued (Allison, 2024). AI systems also reproduce and amplify historical biases embedded in training data, privileging dominant cultural forms while marginalising others (Foka et al., 2025). Visual and narrative outputs often reflect Eurocentric aesthetics, reinforcing colonial continuities in cultural production and raising urgent concerns about diversity and representation in algorithmically mediated creative economies (Arora, 2024).

Chow and Celis Bueno (2024) show how AI tools reconfigure media production workflows under capitalist imperatives of efficiency, reframing creativity as a rhetorical device that obscures the material and relational nature of labour. Tang (2025) extends this critique to the legal domain, arguing that intellectual property law has historically prioritised outputs over creators, facilitating corporate concentration and diminishing bargaining power. In the context of AI, this output-centric paradigm becomes untenable; creative outputs are now abundant, but the labour behind them is increasingly invisible and devalued.

In response, labour organisations and creative communities have mobilised against unregulated AI adoption through strikes, petitions and campaigns such as the 2023 Hollywood strikes and the UK's ‘Make it Fair’ initiative (Nath, 2025). These movements advocate for transparency, opt-in consent and fair licensing models, positioning collective action as essential for recalibrating institutional frameworks. Regulatory efforts, including the European Union AI Act, aim to safeguard creator rights but face trade-offs between innovation and protection, alongside jurisdictional challenges in global digital markets (Nath, 2025).

Australia has yet to confront the legal and economic consequences of AI in any comprehensive way, although it is high on many policy agendas—from the macroeconomic, to IR, and from principles of intellectual property to cultural policy. The 2024 ACTU Congress focused on union concerns relating to workers’ rights and AI (Jerrard et al., 2024) and adopted its first policy statement on AI (Scalmer and MacDonald, 2025). Specific concerns related to ‘intensive monitoring and surveillance, algorithmic management, misuse of personal data, substitution of human labour and theft of creative work’ (Scalmer and MacDonald, 2025: 792). Since the 2024 ACTU Congress, two parliamentary committees have reported on the impact of AI: A report from the Select Committee on Adopting Artificial Intelligence, The Senate, November 2024 and Future of Work—Inquiry into the Digital Transformation of Workplaces, House of Representatives, Standing Committee on Employment, Education and Training, January 2025. Both Inquiries received submissions from unions, professional associations and employer groups.

An interim report of the Productivity Commission released prior to the 2025 Economic Reform Roundtable Summit acknowledges that copyrighted materials are already being used extensively to train AI models without acknowledgement of authors, nor their consent, and for no remuneration (Productivity Commission, 2025: 25). It suggested that the Government consider introducing a wide-ranging text and data mining exception that would remove the necessity to obtain permission from copyright owners (2025: 26). As the government had identified AI as a key driver of productivity improvements, a matter discussed at the Roundtable, this proposal caused much concern among cultural and creative workers (ABC, 2025). At its conclusion, ACTU Secretary Sally McManus told reporters: ‘There's agreement that we’re going to give this a real good go at coming up with a model that makes sure that people are actually paid for what they produce. So that's a big thing’ (SBS, 2025).

However, the rise of AI, and an international focus on labour issues in the cultural and creative sector, has brought into sharp relief the fact that while Revive acknowledges artists as workers, many are not, and cannot, be recognised as employees within the Australian IR system at present, and consequently are excluded from many basic workers’ rights and protections. For the recognition of artists as workers to be more than a merely rhetorical act, a policy ecology lens is necessary; one that illuminates how cultural policy, copyright law, technology governance and IR interact, often incoherently, to condition the possibilities of work and income in the CCIs (Coles and MacNeill, 2017).

Analysis of policy ecologies foregrounds policy as a contested terrain shaped by power relations, institutional legacies and embodied experience (Kirby and Shepherd, 2021; Lea, 2024). As Lea (2024) argues, policies ‘live on as institutions, infrastructures, architectures, historical precedents, rights, constraints, perceptions of the obligatory and the statutory, habits of analysis and inhabitation’, shaping the organisation of social relations across workplaces, families and communities. This conceptual lens enables a more nuanced analysis of how regulatory exclusions are not merely technical oversights but manifestations of deeper structural and institutional dynamics. Policy ecologies assist in making sense of what might otherwise appear to be sectoral anomalies: why, for instance, a cultural policy may affirm the importance of artists as workers deserving of fair remuneration while the labour laws exclude large numbers of artists and cultural workers from collective bargaining, and why creative industries unions, guilds and professional associations are aligning with media conglomerates to oppose proposals from AI aggregators that would weaken copyright protections.

Copyright law structures the terms under which much creative labour is commodified, contracted and remunerated (Towse, 2019). Unlike standard employment relationships, where wages are exchanged for time, creative workers such as writers, musicians, actors and directors often derive income from the licensing of rights to reproduce, perform or adapt their work. In Australia, where this creative output is produced in an employment relationship, the Copyright Act 1968 determines that copyright over the employees’ original creations automatically rests with the employer (Copyright Act, 1968: s35). Outside of an employment relationship, creative outputs are traded: publishing, recording, public performance and image reproduction rights are sold or licensed. The remuneration can take the form of royalties, lump sum payments, or a combination of both. This creates a dual dependency: on the legal recognition of authorship, and on the market value of the work, both of which are now being destabilised by use of AI across the creative industries.

The importance of royalties and advances varies considerably across art forms, often in an inverse relationship to the level of formal employment relationships that exist in the sector. For example, 79% of composers and 63% of writers received income from royalties and advances in the 2021–2022 financial year, compared with an average of 37% across all art forms (Throsby and Petetskaya, 2024: 93). Fewer composers and writers receive income from salaries and wages, and from contracts based on an hourly rate, than other arts practitioners, implying that formal employment arrangements are less common in these artforms (Throsby and Petetskaya, 2024).

The existence of an employment relationship brings about the potential for collective bargaining through union representation, enabling the possibility of a fair reward for the transfer of intellectual property. In the case of individuals producing copyright protected work outside of an employment relationship, the value that they can realise from their copyright is dependent on market power, and collective bargaining on behalf of these professionals is impossible within the Australian IR framework. This was reinforced during the 2023–2024 Modern Awards Review, with the final report observing that ‘a significant proportion of “artists” would fall into the category of a non-employee’, and it ‘is uncontroversial that modern award coverage is limited by the FW Act to national system employees’ (Fair Work Commission, 2024: 6).

Nonetheless, with a degree of ingenuity collaborative forms of negotiation have emerged. Historically, copyright collecting agencies emerged representing both the individual and collective interests of artists (Gervais and Quintais, 2025). In 2021, the Australian Competition and Consumer Commission (ACCC) granted an authorisation to Screen Producers Australia to negotiate with organisations representing directors, actors, writers and technical crew involved in film productions with a view to producing model terms of engagement (ACCC, 2021). The Closing Loopholes amendment to the Fair Work Act 2009 has encouraged some enthusiasm in the CCIs for extending the scope of the ‘employee-like’ categories of employment beyond the current focus on those whose work is determined through digital platforms and those engaged in road transport. Given that the ‘control test’ still lies at the heart of this legislation, and autonomy is a crucial aspect of creative labour, this may be a stretch but could unintentionally stoke an argument over ownership of intellectual property in employee-like arrangements. Nonetheless, the Fair Work Commission itself suggested that some relief might be provided under this legislation where terms in a contract which relate to ‘workplace relations matters’ (as defined in s536JQ of the Act) might be considered unfair (Fair Work Commission, 2024: 6).

AI concerns expressed in submissions

The threat that AI presents to both the demand for human-created content and the income derived from existing works was a theme throughout the submissions to the Senate Select Committee on Adopting Artificial Intelligence (2024) and The House of Representatives Inquiry into the Digital Transformation of Workplaces (2024). This threat occurs through two primary mechanisms: first, the unlicensed input of copyrighted material to train AI systems, effectively appropriating creative labour without consent or compensation; and second, the displacement of human creators by AI-generated outputs, which are increasingly indistinguishable from human work and may even be granted copyright protection themselves. This dual threat represents what Burk calls a ‘synthetic substitute for human creativity’, a shift from the automation of reproduction to the automation of creation, a move that lowers the cost of creativity by bypassing the labour that once produced it (Burk, 2023: 1679–1682). In doing so, AI facilitates a transfer of value from labour to capital, intensifying the structural inequalities that already characterise the CCIs. This is not merely a technological disruption but a reconfiguration of the political economy of cultural production, one that demands urgent attention from IR scholars and policymakers alike.

Input issues: Consent, transparency and licensing

The most frequently cited input issue across submissions is the lack of informed, revocable consent for the use of creative works in AI training datasets. Voice actors, musicians, writers and designers report that their work has been scraped from online platforms without permission, often from pirated sources (Australian Writers’ Guild and AWG Collecting Society, 2024; Media, Entertainment and Arts Alliance, 2024). This practice may constitute a copyright infringement, violates the principle of authorial control and undermines the moral rights enshrined in Australian copyright law, including the right to attribution and integrity. The Australian Association of Voice Actors (AAVA) highlights cases of non-consensual voice cloning, including the use of actors’ voices in pornographic content and children's media (AAVA, 2024). These examples underscore the financial, ethical and reputational risks of AI training practices and call for mandatory consent frameworks that allow creators to opt in or out of AI use.

Transparency is another critical concern. Creators often cannot verify whether their work has been used in AI training, nor can they seek compensation due to the opacity of dataset construction (APRA AMCOS, 2024; Australian Recording Industry Association, 2024). The lack of disclosure prevents courts from adjudicating copyright disputes and undermines the enforceability of rights. Several submissions call for mandatory dataset transparency, including public registries of training materials and clear labelling of AI-generated content (Australia New Zealand Screen Association, 2024; Australian Guild of Screen Composers, 2024; SBS, 2024).

Licensing models are proposed as a solution to the unregulated use of creative inputs. Stakeholders advocate for statutory licensing schemes akin to those used in music and publishing, which would allow creators to receive royalties for the use of their work in AI training and outputs (Australian Guild of Screen Composers, 2024; Australian Writers’ Guild, Australian Writers’ Guild Authorship, Collecting Society, Australian Screen Editors Guild, Australian Production Design Guild, Australian Cinematographers Society, 2024). However, the Australian Digital Alliance (Australian Digital Alliance, 2024) argues that licensing is impractical due to the scale and diversity of content required for AI development and calls for a flexible copyright exception, similar to the existing fair dealing provisions in Australian copyright law. This position is contested by creator groups, who warn that such exceptions would further erode their economic rights and incentivise infringement.

Output issues: Attribution, infringement and market displacement

AI-generated content often mimics the style, voice or likeness of artists without attribution, violating moral rights and diluting artistic identity. Directors, composers and designers report that their distinctive creative signatures are being replicated by AI systems, leading to reputational harm and loss of market value (Australian Production Designers Guild, 2024; Australian Screen Directors Authorship Collecting Society and Australian Directors Guild, 2024). The absence of attribution mechanisms in AI outputs undermines the cultural and economic significance of authorship and calls for reform to extend moral rights protections to derivative AI content.

Many submissions raise concerns about the copyright status of AI-generated works. The Australian Copyright Council (2024) highlights the necessity of human authorship for copyright protection and observes that AI-generated content should not be eligible for protection unless it reflects sufficient human intellectual effort. This position aligns with international norms but creates legal uncertainty for hybrid works involving both human and AI input. Producers and broadcasters express fear of inadvertently infringing third-party copyrights through the use of GenAI tools, which they argue will slow adoption and increases legal risk (Australian Broadcasting Corporation, 2024; Screen Producers Australia, 2024).

Finally, as widespread concerns from across the global economy indicate, AI-generated content competes directly with human-created works, leading to job displacement and income loss across the CCIs. Voice actors report an 80% reduction in work opportunities due to synthetic voice technologies (AAVA, 2024), while journalists and media workers face declining revenue as AI platforms summarise news without attribution or compensation (Free TV, 2024; Nine, 2024). This displacement is particularly acute in entry-level roles and thus argued to be threatening the career pipeline and long-term sustainability of the creative workforce (Australian Guild of Screen Composers, 2024; Australian Writers’ Guild and AWG Collecting Society, 2024).

Numerous submissions emphasise that First Nations creators are particularly vulnerable to the harms of AI. Submissions from Media, Entertainment and Arts Alliance (2024), Arts Law (2024) and the National Aboriginal and Torres Strait Islander Music Office (2024) emphasise the inadequacy of existing protections for Indigenous cultural property. AI systems trained on Indigenous artworks, stories and music without consent perpetuate cultural appropriation and threaten community sovereignty. These groups call for a legislated framework for Indigenous Cultural and Intellectual Property that recognises the holistic and communal nature of Indigenous knowledge systems (Arts Law, 2024; Media, Entertainment and Arts Alliance, 2024).

As noted, Australian copyright law does not recognise AI systems as authors, and reference to case law is necessary to determine the level of human input required for copyright protection. This creates legal uncertainty not only for artists but also for employers, platforms and producers navigating a rapidly changing creative economy. As licensing models break down and legal authorship becomes contested, the effectiveness of copyright as a form of remuneration for creative labour is thrown into question. Without enforceable protections for attribution, consent and compensation, copyright cannot function as a stable or equitable regulatory mechanism.

In this regard, copyright law occupies a unique position in the broader policy ecology of creative work. It mediates between IR, cultural policy and technology governance, yet it remains poorly integrated with labour law and enforcement mechanisms. While cultural policy may promote fair pay and artist recognition, the actual source of many creators’ income remains dependent on a legal regime ill-equipped for AI disruption. The challenge, then, is not only to defend existing rights but to reimagine how copyright, labour law and emerging AI regulation intersect, and where inconsistencies continue to expose creative workers to exploitation and displacement.

Cross-cutting issues of consent, attribution, licensing and market displacement are not simply discrete regulatory failures but symptoms of a disorganised policy ecology. The submissions analysed here reveal how creators are caught between opaque technological infrastructures, fragmented regulatory regimes and underdeveloped enforcement mechanisms. The absence of coordinated governance across copyright, labour law and AI regulation reflects messiness of multiple policy domains and actors, where competing logics and institutional silos undermine the capacity for coherent intervention. Moreover, as Lea (2024) reminds us, these policy failures are not abstract: they shape the lived experiences of creative workers, prefiguring their access to income, recognition and career sustainability. The policy ecology framework thus offers a critical tool for understanding not only the regulatory gaps but the real-world consequences of AI disruption in the CCIs.

What is to be done?

Policy responses to the impacts of AI on creative labour in Australia remain largely fragmented, consultative and non-binding. While Revive represents an important symbolic commitment to artists as workers, its practical implementation mechanisms are underdeveloped. One of the most notable institutional responses is the creation of Creative Workplaces under the Creative Australia Act 2023. Positioned at the nexus of cultural and industrial policy, Creative Workplaces is tasked with improving working conditions in the CCIs, including promoting safe work environments, fair pay and sustainable career structures. However, Creative Workplaces operates without enforcement powers and at a distance from related regulatory domains such as intellectual property law and AI governance. As a result, its influence will depend on voluntary uptake by industry stakeholders and the Australian Government's political will to translate its recommendations into binding reform.

Beyond Australia, international developments offer possible ways forward. In the US, the resolution of the 2023–2024 strikes by the WGA and SAG-AFTRA resulted in significant contractual gains, including explicit consent requirements for the use of an actor's likeness, limitations on AI-generated scripts and provisions ensuring credit and residuals for derivative works (SAG-AFTRA, 2025; WGA West, 2025). These agreements established new boundaries for GenAI technologies, achieved through coordinated industrial action rather than legislative reform. In Canada, the Alliance of Canadian Cinema, Television and Radio Artists (ACTRA) has advocated for similar protections, particularly in response to synthetic voice technologies, digital replicas and deepfakes (ACTRA Toronto, 2025).

Taken together, these international developments demonstrate both the urgency and difficulty of regulating AI in the context of creative labour. They highlight the need for a coordinated, cross-sectoral approach that integrates IR, copyright law and ethical AI governance. For Australia, this moment presents a policy opportunity to coordinate reforms across fragmented jurisdictions. This could include expanding collective bargaining coverage for independent contractors, embedding creator rights in AI governance frameworks and legislating for moral rights enforcement in the digital age. Without such interventions, the disconnect between policy ambition and lived working conditions in the CCIs will only widen.

From an IR perspective, these developments underscore the urgent need to rethink and reform the regulatory framework governing collective organisation and workers’ rights. International examples clearly demonstrate that collective bargaining in this context serves as a powerful industrial strategy to address a regulatory vacuum around AI and creative labour, where individual rights are diffuse and weak, and technological advances outpace legal protections. Conceptually, this underscores the need for an expanded definition of rights that goes beyond wages and working conditions to account for the impact of technology on working lives. Strengthening collective power through legal reform would provide a structured mechanism to assert and enforce these expanded rights, ensure equitable sharing of AI-generated value and enhance the sustainability of creative careers in an AI-driven economy.

Conclusion: Policy ecologies and disorganised governance

In the context of the CCIs, an analysis of policy ecologies, rather than siloed policy domains, helps explain why cultural policy may affirm artists as workers while labour law excludes them from collective bargaining, and why copyright protections are undermined by AI training practices despite nominal legal safeguards. This analytic lens enables a more comprehensive understanding of the regulatory incoherence that characterises creative labour governance and demonstrates the need for comprehensive reform that acknowledges the interdependence of the current frameworks.

The arrival of GenAI has revealed and intensified the incoherence of this policy ecology. It introduces new actors (tech platforms, developers), new forms of production (automated creativity) and new regulatory gaps (ownership of data inputs, attribution of outputs, displacement of human labour). Yet these developments have not been met with a coordinated policy response. Instead, we see disorganised governance: overlapping and poorly aligned regulatory frameworks characterised by jurisdictional ambiguity, inconsistent enforcement and limited institutional capacity. For example, while Revive promotes fair remuneration and sustainable careers, it does not address the absence of collective bargaining rights for self-employed workers. Similarly, copyright law nominally protects authorship and integrity but has offered no recourse for creators whose works are scraped without consent for AI training. Resolving these tensions means operating across the fragmented landscape of cultural policy, copyright law and IR. The regulation of cultural labour in the AI era demands more than piecemeal reforms or sector-specific fixes. It requires an approach that recognises the interdependence of IR, cultural policy, copyright law and digital governance. The policy ecology framework advanced here helps to map this complexity and to identify the institutional misalignments and omissions that expose creative workers to harm. Addressing these gaps will require significant shifts: from voluntary codes to enforceable protections; from siloed policymaking to cross-sectoral coordination; and from symbolic recognition to structural inclusion.

The concept of policy ecologies not only illuminates regulatory complexity; it demands a reorientation of how we protect and empower cultural labour in the digital age. The rapid emergence of GenAI has exposed and intensified the longstanding regulatory gaps that shape creative work in Australia. While Revive has marked a significant cultural policy shift by explicitly recognising artists as workers, this rhetorical revaluation is not yet matched by legal or institutional transformation. The persistent exclusion of freelance creative labour from core industrial protections, combined with the destabilising impact of AI on intellectual property, authorship and income, places cultural workers at the forefront of 21st-century labour market disruption. As this article has shown, these challenges are not only technological or economic in nature, but deeply political and institutional.

Ultimately, the protection of creative labour is not simply a matter of defending jobs. It is about safeguarding the conditions under which culture is made, shared and valued. If the cultural sector is to be future-focused and technology-enabled, as Revive envisions, then the governance of that future must be grounded in justice, inclusion and sustainability for the people who make it possible.