AI Regulation in Japan

AI Promotion Act

On 4 June 2025, Japan enacted the Act on Promotion of Research and Development, and Utilization of AI‑related Technology (the “AI Promotion Act”). This is Japan’s first piece of AI‑specific legislation. Although the AI Promotion Act does not explicitly address its applicability to foreign entities, discussions in the Diet (the national legislature of Japan) clarified that it is expected to apply to them as well. Therefore, foreign entities intending to engage in AI‑related business in Japan should take the AI Promotion Act into consideration.

The AI Promotion Act primarily sets out basic policies for AI research, development, and utilization. It provides a framework for the government’s formulation of AI‑related basic plans, the implementation of basic policies, and the establishment of a national headquarters for AI strategy. Many provisions function as foundational guidelines directed at national and local governments. In addition, the AI Promotion Act anticipates that guidelines will be established to ensure the appropriate research, development, and use of AI‑related technologies in alignment with international norms.

The obligations imposed on private enterprises, set forth in Article 7, are limited. This provision requires any business entity that utilizes AI‑related technologies (an “AI-utilizing business entity”) to co-operate with measures implemented by national and local governments under the AI Promotion Act. Article 7 also encourages AI-utilizing business entities to improve the efficiency and sophistication of their business activities and to foster the creation of new industries through proactive use of AI‑related technologies.

Although the AI Promotion Act does not prescribe penalties, Article 16 authorizes the national government to issue administrative guidance and advice to an AI-utilizing business entity that violates its obligations thereunder. The government may also publicly disclose relevant information, including – when deemed necessary – the name of the violating AI-utilizing business entity.

In accordance with the AI Promotion Act, the government approved the “AI Basic Plan” on 23 December 2025, and the “Guidelines for Ensuring Appropriateness of Research, Development and Utilization of AI‑Related Technology” (the “Guidelines for Appropriateness”) on 19 December 2025. Under the Guidelines for Appropriateness, AI‑utilizing business entities are expected to adhere to the following principles:

  • ensuring holistic appropriateness through AI governance;
  • ensuring transparency to build trust with stakeholders;
  • ensuring adequate safety;
  • maintaining a safe environment by securing business continuity; and
  • considering stakeholders in light of the importance of data as the foundation for AI innovation.

Although the Guidelines for Appropriateness are not legally binding, they are intended to serve as a reference for anyone conducting AI‑related business in Japan.

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Author: Akira Komatsu (Partner)