That's not true. This is from the copyright office's circular on WFH: There are two situations in which a work made for hire is produced: (1) when the work is

That's not true. This is from the copyright office's circular on WFH: There are two situations in which a work made for hire is produced: (1) when the work is created by an employee as part of the employee’s regular duties and (2) when a certain type of work is created as a result of an express written agreement between the creator and a party specially ordering or commissioning the work. neither requires a "certificate of authorship" though one does require an "express agreement" though it need not necc. be a signed writing, let alone a cert of authorship.