By request of advocates from the photo associations on behalf of photographers, the Copyright Office has reversed a 2018 rule that prohibited the use of punctuation in image file names when submitting groups of photographs, for copyright registration, whether published or unpublished.
As of March 15, 2019, photographers no longer need to rename their image files when registering. This welcome change will significantly simplify copyright registration for photographers.
The US Copyright Office has issued a technical amendment to the Federal Rules for Registration of Groups of Published Photographs and Registration of Unpublished Photographs.
The amendment removes this sentence from rules 202.4(i)(9) and 202.4(h)(9): “The file name for a particular photograph may consist of letters, numbers, and spaces, but the file name should not contain any other form of punctuation.” As a result of this technical amendment, claimants submitting applications for copyright registration may include underscores, hyphens and other punctuation in the file names of deposit copies submitted with their copyright registration applications. The amended rules take effect March 15, 2019.
Here is a link to the amendment https://www.federalregister.gov/d/2019-02185/p-86
F. Technical Amendments
The final rule makes a few technical changes intended to clarify the regulations, update cross-references, and simplify the registration of photographs by accepting more formats and material. Specifically, the final rule removes a superfluous sentence from §202.4(h) which states that a group of unpublished photographs cannot be registered as an unpublished collection and removes a provision from §202.4(h) and (i), and §202.20(c), stating that photographers should not include any form of punctuation in the file names that they upload to the electronic registration system. The Office was concerned that punctuation in the file names might cause a technical error that could prevent the system from opening the files, but after testing the new applications the Office has confirmed that punctuation should not cause this type of problem. This represents a change in a “rule of agency organization, procedure, or practice,”  that does not “alter the rights or interests of parties” to require notice and comment? —if anything, it eases the requirements for applicants that use this option