A composition has composers and lyricists. A recording has those people plus everyone who turned it into a master, and each of them can hold something you need signed away.
That is why sound recording filings attract more queries than musical work filings, and why they take longer.
Who has to sign
The arranger or studio producer, not to be confused with the producer who is the author. Whoever built the track. Even where they were paid a flat fee, get the waiver in writing, “we paid them” is a commercial fact, not a documentary one.
Every performer. This is the one that gets missed. Section 38A gives a performer an exclusive right in their performance, independent of the copyright in the recording. A singer who was paid for the session still holds it until they consent. Backing vocals count. A featured instrumentalist counts.
Because section 39A applies sections 18 and 19 to performers’ rights, a performer’s consent is caught by the same rules as an assignment, including the defaults that quietly shrink a document that does not state duration and territory.
The composition’s authors. The recording embeds a musical work. Your recording filing should be able to point at the assignment that gave you the underlying composition, even though that is a separate registration.
Keeping the pile small without leaving gaps
Two rules do it:
- A role shared by several people → one joint document, all of them sign.
- One person holding several roles → one combined document that addresses each capacity in its own numbered clause, so neither can be read as unaddressed.
The second is common in independent music, where the same person often arranges and sings. One document is fine, provided it does not blur the two roles into a single paragraph.
An agreement is an alternative to the whole consent set
This is the part most guides miss, and it is stated in the Office’s own query wording rather than anywhere prominent.
The requirement is phrased conditionally. If a copy of the agreement is not provided, then consents in original from the various rights holders are required. In other words the consent set is what you file because you have no single agreement covering everyone. A properly drafted agreement that already assigns the composition, the arrangement and the performances to the applicant answers the same question in one document.
For most independent releases the consent set is still the practical route, because the agreement usually does not exist and drafting one after the fact means going back to the same people anyway. But if you are setting up a label now, it is worth knowing that papering contributors properly at the outset can replace a stack of per-song consents later.
What a query looks like
When the Office asks for consents on a sound recording, it names the categories it expects, composers and producers and lyricists and singers, rather than naming individuals. Read that list as a checklist and answer every line of it. A reply that covers the arranger exhaustively and does not mention vocals has not answered the question that was asked, however thorough it looks.
Note that it asks for those consents in original. Scans go up to the portal; the signed originals still have to reach Delhi.
One more thing the same query can carry: where an individual is named as the sole creator of the recording, the Office asks for an affidavit confirming that. So the answer you give in the author column can decide whether you also have to produce a notarised affidavit to support it.
Notarised originals, posted
Wet ink, a Notary Public’s seal and signature on the document itself, and the originals in the physical packet. No stamp paper is needed for a consent of this kind. Both sides sign: the person consenting, and the company accepting.
Scan the signed set for the upload, but the originals still have to travel.