A multi-jurisdiction IP strategy decides, market by market, whether each trademark, design or patent goes through a national office, a regional office such as the EUIPO, OAPI or ARIPO, or an international system such as Madrid, Hague or the PCT. The choice changes cost, timing and how exposed the portfolio is if one filing fails. This decision matrix is built on the official membership lists and is meant for in-house teams planning protection across Europe, Latin America and Africa.
Key takeaways
- There are three families of routes: national filings, regional offices and WIPO’s international systems. Most corridor portfolios need all three.
- Membership decides first. The Hague System had 85 contracting parties on 14 July 2026 and the PCT 159 states on 19 May 2026, but key markets such as Argentina, South Africa and Nigeria sit outside one or more of them.
- Regional titles bundle many countries: one OAPI title covers 17 African states, and one EU trade mark covers 27 Member States, but both are all-or-nothing.
- International systems centralise filing, not protection. A Madrid registration depends on its base mark for five years, and a PCT application never becomes a patent by itself.
What is a multi-jurisdiction IP strategy?
It is the set of decisions that turns a list of markets into a list of filings. For each right, the question is the same: which offices grant protection in the countries that matter, and which combination reaches them at the lowest cost and risk? The three families of routes work differently:
- National filings go directly to each country’s office and produce titles that are independent of one another.
- Regional offices grant one title for a group of countries: the EUIPO (European Union Intellectual Property Office) for EU trade marks and designs, OAPI (the African Intellectual Property Organization) for its 17 member states, and ARIPO (the African Regional Intellectual Property Organization), which lists 22 member states. The EPO (European Patent Office) grants European patents that are then validated country by country.
- International systems administered by WIPO (the World Intellectual Property Organization) centralise the filing: Madrid for trademarks, Hague for industrial designs and the PCT (Patent Cooperation Treaty) for patent applications.
The decision matrix: national, regional or international filing?
| Route | What one filing gives you | Fits best when | Main risk |
|---|---|---|---|
| National filing | An independent title in one country | One or two markets, or countries outside the international systems | Cost and admin multiply with each country; local agent needed abroad |
| EU trade mark or EU design (EUIPO) | One unitary right for 27 Member States | Sales in several EU countries | All-or-nothing: a conflict in one Member State can block the whole application |
| OAPI | One title valid in 17 West and Central African states | Any business in francophone West and Central Africa | No national alternative in those states; one invalidation affects all 17 |
| ARIPO | A regional filing designating member states, mainly in English-speaking Africa | Several ARIPO markets at once | Each designated state can refuse effect; coverage differs by protocol |
| EPO (European patent) | One examination and grant, then validation in chosen states, including validation states such as Morocco | Patents for several European markets | Validation and renewal costs per country after grant |
| Madrid (trademarks) | One international application designating member countries | Many markets that are all in Madrid | Central attack: designations fall if the base mark falls within five years |
| Hague (designs) | Up to 100 designs in one international application | Design portfolios across Hague members | Several corridor markets are not members |
| PCT (patents) | One international application and search, with national phase decisions deferred | Uncertain markets or budgets; time to test the invention | National phase deadlines, usually 30 months from priority, cannot be missed |
The Madrid dependency rule comes from Article 6(3) of the Madrid Protocol; if the base mark falls, Article 9quinquies allows conversion into national applications within three months. The EUIPO explains that an EU trade mark is an all-or-nothing deal that can be converted into national applications where the problem does not arise. WIPO’s PCT FAQs confirm that the grant of patents remains with national or regional offices.
Who belongs to which system across the corridor?
The matrix only works once you know which countries can be reached by each route. This table is drawn from WIPO’s status lists for the Hague Agreement (14 July 2026) and the PCT (19 May 2026), and from WIPO Lex for the Madrid Protocol.
| Market | Madrid | Hague | PCT |
|---|---|---|---|
| Spain | Yes (and via the EU) | Yes (and via the EU) | Yes |
| Portugal | Yes (and via the EU) | Via the EU | Yes |
| Mexico | Yes | Yes | Yes |
| Brazil | Yes | Yes | Yes |
| Colombia | Yes | No | Yes |
| Chile | Yes | No | Yes |
| Peru | No | No | Yes |
| Argentina | No | No | No |
| Morocco | Yes | Yes | Yes |
| Egypt | Yes | Yes | Yes |
| South Africa | No | No | Yes |
| Nigeria | No | No | Yes |
| Kenya | Yes | No | Yes |
| Ghana | Yes | Yes | Yes |
| OAPI (17 states) | Yes | Yes | Yes (all 17 states) |
Two practical readings follow. Argentina sits outside all three systems, so every right there is a national filing. And Colombia, Chile and Peru, important Andean and Pacific markets, cannot be reached through Hague, so design protection there means national applications.
How to read the matrix: four questions
- How many markets, and are they in the same system? Madrid or Hague pays off when most target countries are members. With two or three markets, national filings can be simpler.
- When do you need to spend? The PCT postpones most national costs to around month 30, which suits companies still testing markets or raising funds.
- How robust is the home filing? A base mark that may be challenged at home makes Madrid riskier; consider an EU trade mark or national filings in the key markets.
- Where will you enforce? Enforcement is always local. A regional title still has to be enforced before the courts of the country where the infringement happens.
What this means for your business
- Start from a market list ranked by revenue, manufacturing and risk of copying, not from a route.
- Map each market against the membership table, right by right.
- Group the markets: one Madrid or Hague filing for members, a regional filing where it covers several targets, national filings for the rest.
- Diarise the deadlines that create the most risk: the Paris Convention priority year for patents and the six-month priority for trademarks and designs, PCT national phase entries and the end of Madrid’s five-year dependency period.
If you want this mapping done for your portfolio, our multi-jurisdiction IP strategy service builds the route plan and the budget together. For patent-heavy portfolios we coordinate with European patent attorneys; see our patent filing service across Europe, Latin America and Africa.
Where multi-jurisdiction filing strategies go wrong
- Choosing the route before the markets. A company that files through Madrid by default can end up with no protection in Argentina, Peru or South Africa.
- Missing priority deadlines. Once the priority period has passed, a later filing abroad loses the earlier date, and your own disclosures or third-party filings in the meantime may destroy novelty or create conflicts.
- Ignoring the all-or-nothing effect. One earlier national mark can block an EU trade mark application across the Union, so clearance has to cover the whole region.
- Splitting the portfolio among unconnected advisers. Inconsistent specifications, owners recorded differently in each office and missed renewals are the usual result; centralised coordination prevents them.
Frequently asked questions
Is there a single filing that covers Europe, Latin America and Africa?
No. Madrid, Hague and the PCT centralise the filing, but each covers only its members, and several corridor markets are outside them. Argentina, for example, is not in Madrid, Hague or the PCT. A corridor portfolio therefore combines international, regional and national filings, ideally planned together from the start.
When is a national filing better than Madrid?
When there are only one or two target countries, when the base mark is vulnerable at home, or when the market is not a Madrid member. A national title is independent of any base mark, so it is not exposed to central attack, although it costs more to maintain when the number of countries grows.
Does a PCT application give me an international patent?
No. The PCT gives one international application, an international search and more time to decide. To obtain patents you must enter the national or regional phase, usually within 30 months of the priority date, and each office then decides on grant under its own law.
Can IP Global Guard design a multi-jurisdiction filing plan for us?
Yes. We map your markets against each system, recommend the combination of national, regional and international routes and coordinate the filings: directly when our professionals are entitled to act before the office concerned, otherwise through qualified representatives, with local correspondents in Latin America and Africa and European patent attorneys for EPO work.
How IP Global Guard turns the matrix into a filing plan
A decision matrix is only the start; what protects a business is a filing plan that is executed on time in every office. IP Global Guard, the IP services line of META Channel Corporation Limited, plans and manages trademarks, designs and patents across more than 25 jurisdictions in Europe, Latin America and Africa with one strategy, one point of contact and one billing relationship. Our jurisdiction coverage shows where we coordinate filings.
Tell us which rights you need to protect and in which markets you sell, manufacture or plan to launch. We will map each market to the right route and return a filing plan with deadlines and official fees. Contact our strategy team.
This article is general information, not legal advice, and membership of each system should be checked on the filing date.
Sources
- WIPO, Hague Agreement: status on 14 July 2026 (85 contracting parties)
- WIPO, Patent Cooperation Treaty: status on 19 May 2026 (159 states)
- WIPO Lex, Madrid Protocol contracting parties
- WIPO Lex, Protocol Relating to the Madrid Agreement (Articles 6 and 9quinquies)
- WIPO, PCT frequently asked questions
- WIPO, The Hague System
- EUIPO, Where to register a trade mark
- OAPI, official website (member states)
- ARIPO, Member states
- EPO, Validation states
