EPO: Enlarged Board confirms old disclaimer practice

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

EPO: Enlarged Board confirms old disclaimer practice

The EPO's Enlarged Board of Appeal (EBA) recently issued its long-awaited decision G 1/16 relating to undisclosed disclaimers. The decision lays down under which circumstances the introduction during prosecution of a patent application before the EPO of a disclaimer not disclosed in the application as filed may be allowable under Article 123(2) EPC. The decision essentially confirms the standard defined in decision G 1/03 of 2004.

Decision G 1/16 is the third EBA decision dealing with disclaimers. In decision G 1/03 of 2004, the EBA ruled that an undisclosed disclaimer may be allowable, in spite of support in the application as filed, to restore novelty over prior art cited under Article 54(3) EPC (i.e. a prior European patent application not published at the filing date of the application under examination), to restore novelty over an "accidental" anticipation, or to remove subject-matter excluded from patentability for non-technical reasons.

Later on, in 2011, the EBA scrutinized the allowability of disclaimers which do in fact have a basis in the application as filed. In the decision dealing with that issue, G 2/10 of 2011, the EBA arrived at the conclusion that a disclosed disclaimer is allowed only if the subject-matter remaining in the claim after the introduction of the disclaimer is directly and unambiguously derivable from the application as filed. It did, however, remain unclear whether or not this standard should apply also to undisclosed disclaimers.

The uncertainty to this effect has now been removed by decision G 1/16, according to which the "directly and unambiguously derivable" criterion – the so-called "gold standard" – does not apply to undisclosed disclaimers. Rather, the EBA expressly endorses the practice developed in decision G 1/03, whilst underlining that an undisclosed disclaimer may not provide a technical contribution, notably in relation to the assessment of inventive step or for the question of sufficiency of disclosure.

frederiksen.jpg

Jakob Pade Frederiksen


Inspicos P/SKogle Allé 2DK-2970 HoersholmCopenhagen, DenmarkTel: +45 7070 2422Fax: +45 7070 2423info@inspicos.comwww.inspicos.com

more from across site and SHARED ros bottom lb

More from across our site

Speaking to Managing IP at Via’s Bridge Summit in San Francisco, president Kevin Mack explains why the AI infrastructure boom is forcing a rethink of traditional SEP licensing and FRAND models
Law firms continue to sell clients on international footprints, but sprawling office networks count for little if financial structures discourage internal collaboration
Via's Qi pool expands its footprint in Asia with the addition of Chinese smartphone giant and Japanese auto company
Matthew Cassie becomes the tenth partner to join the firm’s London outpost, and the second since it opened its new headquarters in May this year
A&O Shearman and Fish & Richardson invested in German talent, meanwhile, major firms have assembled for an on the merits case pitting KeeeX against OpenAI and Adobe
Julia Bishop is director of IP at Twilio in the US
Hellberg is an IP director at Essity in Sweden
Palińska is the business & IP law lead at CD Projekt Red in Poland
Teemu Itälä is head of legal and compliance for technology standards at Nokia in Finland
Schwitulla is the head of litigation management at Nokia in Germany
Gift this article