Patents protect inventions for up to 20 years from filing, but only in countries where they are granted, and only if the invention is new when the first application is filed. The usual cross-border route is a first national filing, a Patent Cooperation Treaty (PCT) application within 12 months, and national or regional phase entry at around 30 months. In Europe the Unitary Patent and Unified Patent Court, in operation since 1 June 2023, cover 18 EU states but not the UK.
Novelty, priority and the PCT timetable
Novelty is lost by public disclosure before filing in most countries. The United States is an exception with a one-year grace period for the inventor's own disclosure. A first filing gives a 12-month priority right to file abroad; the PCT then gives about 30 months to enter national phases in chosen countries, as Singapore illustrates with entry at the 30th month. India, Saudi Arabia, the UAE, the UK and the US are all PCT members.
Some countries restrict foreign filing of inventions made locally: Singapore residents need national security clearance from IPOS before filing abroad first. Patentability also varies; the UK excludes business methods, mental acts and mathematical methods as such.12345678910
Term, cost and the European system
Patent terms are 20 years from filing in the UK, the US, Germany and the UAE, subject to renewal fees. A UK application costs at least GBP 405 in official fees and is published about 18 months after filing. The UAE allows compulsory licences where a patent is not used or insufficiently used three years after grant.
A European patent granted by the EPO can take unitary effect in the 18 participating EU states, and the Unified Patent Court hears infringement and validity across them. Holders of classic European patents can opt out of the court's jurisdiction. The UK is outside both systems, so UK validations are litigated in UK courts.111213141516171819
| Market | Term | PCT | Source |
|---|---|---|---|
| United Kingdom | Up to 20 years from filing | Member since 1978 | Patents Act 1977 s25; WIPO |
| United States (federal) | 20 years from US filing date | Member since 1978 | 35 U.S.C. 154 |
| Germany | 20 years from day after filing | Member; Unitary Patent state | PatG § 16; EPO |
| UAE (federal) | 20 years (utility certificate 10 years) | Accepts PCT applications | Federal Law 11 of 2021 |
| India | Not confirmed | Member since 1998 | WIPO |
| Saudi Arabia | Not confirmed | Member since 2013 | WIPO |
| Singapore | 20 years from filing | National phase at 30 months | IPOS |
Decisions to make
- Has the invention been disclosed, or will it be before filing?12Prior disclosure can destroy novelty; only some countries, such as the US, give a limited grace period.
- Where will the first application be filed, and does any foreign-filing restriction apply?39The first filing starts the 12-month priority clock, and Singapore residents need clearance before filing abroad first.
- Unitary Patent, classic European patent or national patents?171819The Unitary Patent covers 18 EU states in one right and is litigated centrally; the UK needs a separate validation.
- Which national phases at 30 months?45National phase entry is when most cost arises; the choice should follow the commercial plan.
Documents usually needed
- Invention disclosure with dates and inventors
- Prior art search results
- Priority application and filing receipt
- Inventor assignments or employment terms establishing ownership
- Renewal fee schedule for each granted country
Common mistakes
- Publishing or pitching an invention before filing
- Missing the 12-month priority deadline
- Filing abroad from Singapore without security clearance
- Assuming a Unitary Patent covers the UK
- Letting renewal fees lapse in key markets
Questions businesses ask
Does a PCT application give a worldwide patent?
No. It is a single filing procedure; protection depends on national or regional grants after national phase entry, at about 30 months.45
Can I opt out of the Unified Patent Court?
Holders of classic European patents can opt out and can withdraw the opt-out unless an action has been brought.19
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- India's national phase deadline, patent term and official fees were not confirmed on an official page.
- Saudi patent term and fees were not researched.
- EPO and Unitary Patent fees, and US patent fees, were not researched.
- The length of the UPC transitional opt-out period was not confirmed.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
To be patentable in Singapore an invention must be new, involve an inventive step and be capable of industrial application, and patent protection is territorial. Prior public disclosure can destroy novelty.
Reused from sg-ip-007.
An inventor's own disclosure made one year or less before the effective filing date is not prior art against the inventor's US patent application. Federal; first-inventor-to-file system under the America Invents Act. Most other patent systems do not have an equivalent general grace period.
Statutory text read on the Cornell Legal Information Institute reproduction of the United States Code; the official text is published at uscode.house.gov. The comparison with other systems is not from the source. Reused from us-ip-007.
A French patent filing at the INPI gives a 12-month priority right to extend protection abroad, through a European patent application at the EPO, a European patent with unitary effect covering the 18 states that have ratified the unitary patent agreement, or a PCT international application covering more than 150 countries. European patents are maintained by paying fees to each national office after grant; unitary patents and classic European patents can be litigated before the Unified Patent Court.
Reused from fr-ip-g02.
UK applicants can seek patent protection abroad through a PCT application (with about 30 months to enter the national phase in chosen countries) or a European patent application at the EPO covering more than 30 European countries including the UK, and can claim priority from a UK application if they file abroad within 12 months. The UK IPO acts as a PCT receiving office. A granted European patent becomes separate national patents in the designated countries.
Reused from gb-ip-g14.
Patent applicants can enter the Singapore national phase from a PCT international application, which IPOS shows taking place at the 30th month.
The page does not state expressly that the 30 months run from the priority date, though that is the PCT standard. Reused from sg-ip-009.
India is party to the Patent Cooperation Treaty, in force for India since 7 December 1998. Instrument deposited 7 September 1998.
Reused from in-ip-002.
The Patent Cooperation Treaty (PCT) and the Patent Law Treaty have been in force for Saudi Arabia since 3 August 2013.
Reused from sa-ip-004.
The Ministry accepts international patent applications filed under the Patent Cooperation Treaty. Federal; national-phase rules and fees in Article 38.
Reused from ae-ip-008.
A person resident in Singapore who wants to file a patent application abroad first must obtain national security clearance from IPOS beforehand.
Reused from sg-ip-008.
To be patentable in the UK an invention must be new, inventive and something that can be made or used, a technical process or a method of doing something; business methods, mental acts, discoveries, scientific theories, mathematical methods, medical treatment methods, artistic works and software with a non-technical purpose are excluded. UK IPO plain-language summary of patentability.
Reused from gb-ip-g09.
A UK patent takes effect on publication of the notice of grant and lasts up to 20 years from the filing date, provided renewal fees are paid. Patents Act 1977 s25(1) and (3).
Reused from gb-ip-g11.
A US utility patent term ends 20 years from the US filing date, or from the filing date of the earliest US or international application specifically referenced under the continuation provisions. Federal. Term adjustments and extensions can apply.
Statutory text read on the Cornell Legal Information Institute reproduction of the United States Code; the official text is published at uscode.house.gov. Reused from us-ip-006.
A German patent lasts twenty years, starting on the day after the application is filed. Subject to payment of annual fees (not reviewed here).
Reused from de-ip-005.
Under Federal Law No. 11 of 2021 on Industrial Property a patent is valid for 20 years and a utility certificate for 10 years from the application date. Federal. The law took effect six months after Official Gazette publication (Article 80).
Reused from ae-ip-006.
A UK patent application costs at least £405 in UK IPO fees, is published about 18 months after filing, and examination can take place several years after filing. The £405 covers application and processing fees; patent attorney costs are additional and the UK IPO describes them as potentially several thousand pounds.
Reused from gb-ip-g10.
The UAE federal industrial property law of 2021 allows compulsory licences, including where a patent has not been used, or has been insufficiently used, for three years after grant. Federal; grounds and conditions in Article 25, court procedure in Article 29, public-interest licences by the Minister in Article 30.
Independent check 19 Oct 2026: the article text matches; the law number shown in the official PDF title is blank, so the number is not stated here. Reused from ae-ip-009.
The Unitary Patent is available only for EU Member States in enhanced cooperation; 18 states currently participate and up to 25 EU Member States may eventually do so, and the United Kingdom is not among them. A European patent can still be validated in the UK as a national patent; the UK is an EPO member state.
The EPO page lists the participating and enhanced-cooperation states; the UK's absence is inferred from those lists, which include only EU Member States. The statement that the UK is an EPO member state is supported by the UK IPO page on protecting patents abroad (gb-ip-g14). Reused from gb-ip-g15.
The Agreement on a Unified Patent Court entered into force on 1 June 2023, and the Court is common to eighteen EU member states. France is a participating state.
Reused from fr-ip-g03.
Holders of and applicants for classic European patents, and holders of related supplementary protection certificates, can opt out of the Unified Patent Court's jurisdiction, and an opt-out can be withdrawn at any time unless an action has been brought before a national court. The length and status of the transitional period were not stated on this page.
Reused from fr-ip-g04.
Questions on this topic
19 statements on patents and the pct
