AI Watch: Global Regulation Tracker – Japan | White & Case LLP

AI For Business


Japan has adopted a soft-law approach to AI governance, but lawmakers are proposing a hard-law approach for certain harm.


Laws/regulations that directly regulate AI (AI regulations))

On May 28, 2025, the Japanese Congress enacted a bill that would establish a new law centered on promoting AI, titled “Act on Promotion of Research and Use of Artificial Intelligence-Related Techniques” (AI Bill).1 The AI ​​bill is Japan's first law to explicitly regulate AI. The bill says the government will establish an AI Strategy Center (and more explanation), which is likely to be released in the summer of 2025, with the basic AI plan likely to be implemented within a year.

Japan previously supported the soft law approach through Business's AI guidelines published in April 2024, and was later updated in December 2024 and March 2025 (“Business Guidelines”).2 However, in August 2024, the Cabinet Office established an AI facility research group and was obliged to consult with various stakeholders to determine the next step in Japan's AI regulation. On February 4, 2025, they published a preliminary summary of their findings.3 The fundamental principle of the group's findings was to promote AI innovation within Japan while mitigateing risks.

The AI ​​Bill mainly focuses on establishing core principles for the research, development and use of AI, developing the government master plan for AI, implementing basic national policies, and establishing the AI ​​strategy center.

Most of that provisions point to future legislation and policy frameworks related to the goals surrounding AI rather than imposing specific requirements. There are regulations that directly affect private companies and place liability on AI developers, AI providers, and business users (each “AI business actors”). for example:

Article 7 – The obligation of AI business actors to use AI to make reasonable efforts to improve the efficiency and overall level of business in line with the core principles of the bill.

Articles 4 and 5 – Provide national or local government agencies with the authority to create policies that affect AI business actors.

Article 16 – The duty of an AI business actor is to cooperate with investigations and/or guidance given by governmental organizations.

Article 25(2) – Provides AI Strategy Center with the general ability to request cooperation from entities that are deemed necessary to carry out their duties.

The AI ​​bill itself does not provide for fines or fines for failing to cooperate. However, Article 16 provides a wide range of authority to take measures based on investigations conducted by the government. One such measure the government is considering is to publicly name companies that refuse to cooperate, but the bill does not have any specific provisions.
The AI ​​bill itself does not provide detailed guidance to AI business actors, but Article 13 states that the government will continue to publish the latest guidelines on the appropriate research, development and use of AI.

Separately, Japan has published the Hiroshima International Guiding Principles, an organization that develops advanced AI systems (Hiroshima Principles) that aims to establish and promote guidelines around the world for safe, safe and reliable AI.4


AI Regulation Status

As mentioned above, the AI ​​bill was approved by the Cabinet Office on February 28, 2025 and by Parliament on May 28, 2025. The AI ​​Strategy Center is likely to start in the summer of 2025, and basic AI plans are expected to begin implementation within the year.

Other laws affecting AI

Various laws have not been specifically adopted to regulate AI, but they may affect the development or use of AI in Japan. A non-exhaustive list of important examples includes:

  • The Digital Platform Transparency Act places requirements on large online malls, app stores and digital advertising businesses to ensure transparency and fairness in transactions with business users
  • Financial instruments and exchange laws that require companies engaged in high-speed trading of algorithms to register with the government, establish risk management systems, and maintain transaction records.
  • Civil law permits claims of tort brought about by those who gave instructions to AI
  • Copyright and Laws on the Protection of Personal Information Applicable to Inappropriate Use of AI

There have also been efforts to legislate taking down and preventing fake or incorrect content. On May 9, 2024, the Information Distribution Providers Act (amendments to the existing Providers Liability Liability Liability Act) was passed by Meal (National Assembly of Japan) with the aim of promoting content takedown requests. Even if the AI ​​doesn't address the content generated rather than AI-specific laws, draft points of discussion are called a way to address the risks arising from AI.

Furthermore, various acts, including AI, may already be viewed in criminal law. You may use AI to remove another act. Using fake content generated by AI to interfere with someone's business can be punished as a disturbance to your business. Also, giving fraudulent commands to another person's computer could be punished under criminal law.

Definition of ai

“Artificial intelligence-related technologies” are defined under Article 2 of the AI ​​Bill. In other words, it is a technology necessary to realize the ability to substitute human cognitive, reasoning, and judgment abilities through artificial means. It also includes technologies related to information processing systems that use such technologies to process information and use the resulting results to process information.

Territory range

The AI ​​bill does not clearly set the scope of the territory, but Article 16, which provides for the obligation to cooperate with the government's investigation, states that the government will analyze information on the development and use of AI both at home and abroad. Furthermore, the AI ​​bill does not distinguish between land and offshore entities in the definition of research institutions or AI business actors. However, the scope may be further refined by the AI ​​Strategy Center when implementing a basic AI plan.

Scope of department

The AI ​​bill applies widely to AI developers, AI providers and business users regardless of sector.

The role of compliance

As mentioned above, private companies are obligated to make reasonable efforts to use AI in accordance with the core principles of the bill. They must also cooperate with government investigations into the development and use of AI. AI business actors should request guidance, advice, or something that the government may issue after investment.

Core Issues AI Regulations Are Troubled

The AI ​​bill states that its central principle is to promote competitive productivity, ensure transparency and promote productivity by advancing basic AI research and HR development. While advancing these goals, the government aims to investigate and guide organizations from inappropriate use of AI. This is a use that can lead to violations of rights and violations of prosperity.

Furthermore, Hiroshima's principles identify several important risks, such as “disinformation, copyright, cybersecurity, health and safety risks, and social risks” (for example, how advanced AI systems cause harmful bias and discrimination).

The government points out the following risks as Japan's priorities: safety, privacy and fairness, national security and crime, property protection, intellectual property.

Furthermore, in regards to copyright, there is a detailed discussion in Japan about how existing laws (i.e., Japanese copyright laws) should address issues relating to the harm that can arise from generation AI. Additionally, the Council of Cultural Affairs has issued a copyright position where AI is trained in human works and the content generated in AI.5

Risk classification

There are no specific risk categories defined in the AI ​​bill. The government-granted investigation rights are intended for the research, development or use of AI for inappropriate purposes. Inappropriate purposes are widely explained as potentially breaching your rights and harming your prosperity.

Key Compliance Requirements

As mentioned above, the AI ​​bill does not provide for detailed compliance obligations, but AI business actors and research institutions require that they cooperate with the investigation and follow the guidance.

Current business guidelines provide specific general principles that AI business actors expect to incorporate into the training and deployment of products and services.6 However, it is up to each AI business actor to decide how to make the principles effective. The principles are as follows:

  • Human-centered – The use of AI must not infringe on basic human rights guaranteed by constitutional and international standards
  • Safety – Each AI business actor avoids damage to the lives, bodies, minds and property of stakeholders
  • Fairness – Eliminating unfair and harmful biases and discrimination
  • Privacy protection – Each AI business actor respects and protects privacy
  • Ensure security – Each AI business actor ensures security that prevents AI's actions from being unintentionally altered or stopped by fraudulent operations.
  • Transparency – Each AI business actor provides stakeholders with necessary and technically possible reasonable information, while ensuring the verifiability of the AI ​​system or service.
  • Accountability – Each AI business actor is responsible for stakeholders to ensure traceability based on the role and degree of risk of each AI business actor brought about by the AI ​​system or service, and is compliant with common guiding principles.
  • Education/literacy – Each AI business actor is expected to provide those engaged in education on knowledge, literacy and ethics regarding the use of AI in a socially correct way, and to stakeholders with education on complexity, misinformation and potentially intentional misuse.
  • Ensuring fair competition – Each AI business actor is expected to maintain a fair competitive environment, so that new businesses and services using AI are created
  • innovation – Each AI business actor is expected to promote innovation and take into account interconnectivity and interoperability

Regulatory Authorities

The AI ​​Bill does not specify a regulatory body to conduct the investigation, but the AI ​​Strategy Center is responsible for creating and implementing basic AI plans. Furthermore, the following ministries and agencies have been working essentially to establish and promote guidelines on AI:

  • Ministry of Economy, Trade and Industry
  • Ministry of Home Affairs and Ministry of Communication
  • Institutions for cultural issues (especially on copyright issues)
  • Personal Information Committee

Guidelines promulgated by Japanese ministries are often closely followed by businesses and the public, despite not binding laws.

Enforcement power and punishment

As mentioned above, the AI ​​bill imposes a duty to make reasonable efforts as follows: (i) Use AI in accordance with the bill's core guiding principles; (ii) cooperate with the investigation. (iii) follow the guidance issued as a result. Although there are no specific penalties or fines associated with refusing to cooperate, the AI ​​bill gives the government a broad power to take action that it believes is necessary based on the investigation and fulfills its obligations.

1Please refer to Acts related to promoting research and development and the use of AI-related technologies (Japanese).
2Click here for AI guidelines for Business Version 1.1.
3 See here for a preliminary summary published by the AI ​​Regulation Research Group.
4Please refer to Hiroshima International Guiding Principles for organizations developing advanced AI systems here.
5 See here for a general understanding of AI and copyright (March 15, 2024). An English overview is available here.
6 See AI guidelines for Business Version 1.0 (here), Part 2C

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