
This article examines how national legal structures affect the reception of the European Union framework for digital preservation and public-domain access outside the Union. Articles 6, 7 and 14 of Directive 2019/790 provide the benchmark. They address preservation copying by cultural heritage institutions, protection of exceptions against contractual restrictions and their connection with rules on technological protection measures, and the exclusion of new copyright or related rights in non-original reproductions of public-domain visual art. The analysis identifies two regulatory configurations among EU Member States: copyright-centered implementation of the Directive, and copyright implementation operating alongside non-harmonized national public-law controls over cultural heritage reproductions. Ukraine and Türkiye are examined as two ways of responding to EU copyright rules. Ukraine has moved closer to the EU model through copyright reform and participation in European digital cultural heritage initiatives. Its legislation already covers some functions reflected in Articles 6 and 14, but gaps remain. These include contractual override, the use of works for preservation when technological protection measures prevent access, and the status of non-original reproductions of public-domain visual art. Türkiye follows a different approach. Copyright, legal deposit, and cultural heritage rules regulate these issues separately. Electronic legal deposit supports preservation through the National Library, but there is no copyright exception allowing cultural heritage institutions to preserve collections. Administrative permissions and controls also affect the creation and reuse of cultural heritage reproductions. The comparison identifies three modes of functional reception–direct legal transmission, institutional and procedural transmission, and functional convergence–and treats non-transmission as a separate category for EU functions left unperformed. In the cases examined, reception is more complete where copyright permissions, technological safeguards, legal-deposit mechanisms and cultural heritage administration are institutionally coordinated. Equivalent protection for preservation and public-domain access depends on the coordinated legal and institutional effects of the national framework.
copyright and cultural heritage; cultural heritage digitization; digital preservation law; public-domain art; EU Copyright Directive; copyright exceptions; technological protection measures; Ukraine; Türkiye