Images on
Commons need to be free in the US and the country of origin.
If I
understand correctly, these images are from the
UK, but the PD status to
pre-1923 images only applies to US images.
That's interesting. How does this apply to the National Portrait Gallery
images then? These were copies of a British digitization which, under UK
copyright law, qualifies as a new item subject to copyright.
That's what the NPG and most medias say, but it is not even sure. Here
is an opinion by a professional UK lawyer: