The last I read it's the exact same in the US. It requires 'substantial human intervention' which is going to be quite open to interpretation. The monkey selfie [1] issue is relevant. Setting up the gear to enable monkeys to take selfies was ruled ineligible for copyright: "only works created by a human can be copyrighted under United States law, which excludes photographs and artwork created by animals or by machines without human intervention."

[1] - https://en.wikipedia.org/wiki/Monkey_selfie_copyright_disput...

Maybe the human profession of the future is some sort of “Shabbos Dev”, providing enough human intervention in the coding to make the code copyrightable.