Analyzing critical legal trends and developments across data, cyber, AI and digital regulations from around the world and beyond borders

On February 28, 2025, the Japanese government submitted the “Bill on the Promotion of Research, Development, and Utilization of Artificial Intelligence-Related Technologies” (the “Japan AI Bill”) to the National Diet. The bill was passed by the House of Representatives on April 24, 2025, and is currently under deliberation in the House of Councillors. If enacted, it will become Japan’s first comprehensive legislative framework governing artificial intelligence.

Legislative Context and Policy Drivers

The Japan AI Bill is a foundational statute aimed at accelerating domestic AI innovation while addressing emerging societal and ethical risks. The legislation reflects growing governmental concern that Japan is falling behind global peers in AI investment and adoption. According to Stanford University’s 2025 AI Index Report, Japan’s private AI investment in 2024 totaled just $0.93 billion—significantly lower than the United States ($109.08 billion), China ($9.29 billion), and the United Kingdom ($4.52 billion), and also behind regional counterparts such as the UAE, Israel, South Korea, and India.

A 2024 survey by the Ministry of Internal Affairs and Communications further revealed that only 9% of individuals and 47% of companies in Japan were utilizing generative AI, underscoring the urgency for a national strategy. One contributing factor may be public concern over AI safety. Government-published material indicates that only 13% of Japanese individuals feel safe using AI under the current legal framework.

Key Features of the Japan AI Bill

The bill is structured as a “fundamental law,” establishing guiding principles and policy mandates rather than imposing direct regulatory obligations or penalties. Key provisions include:

  • Basic Principles for AI Development and Use: Emphasizes enhancing international competitiveness, promoting the comprehensive and systematic development and utilization of AI, ensuring transparency in AI processes, and fostering international cooperation.
  • Defined Responsibilities for Stakeholders: Assigns roles to national and local governments, research institutions, businesses, and citizens. Businesses are expected to actively leverage AI to improve productivity, enhance operations, and foster new industries. They are also required to cooperate with policy measures implemented by national and local authorities.
  • Government Policy Measures: The national government is tasked with several policy measures, including promoting research and development, developing and sharing infrastructure necessary for AI advancement, monitoring global AI trends, and establishing countermeasures against misuse that infringes on individual rights.
  • National AI Strategy: Mandates the formulation of a comprehensive national plan for AI development and utilization.
  • Establishment of an AI Strategy Headquarters: A central body will be created to coordinate policy planning and implementation.

Importantly, while the bill requires cooperation from businesses, it does not impose penalties for non-compliance.

Supplementary Resolution: Ethical and Enforcement Considerations

The bill is accompanied by a non-binding supplementary resolution outlining key considerations for enforcement, including:

  • Ensuring AI development and utilization align with the “Human-Centered AI Society Principles,” safeguarding human dignity and promoting ethical alignment.
  • Strengthening enforcement against the misuse of AI for deepfake pornography, particularly involving minors, through enhanced content removal protocols and victim protection.
  • Balancing regulatory oversight with the protection of trade secrets and intellectual property, while avoiding excessive burdens on businesses. However, the government reserves the right to consider more robust measures for high-risk non-compliance.

Strategic Implications for Businesses

The Japan AI Bill marks a pivotal step in the country’s AI governance landscape. Unlike the EU AI Act, Japan’s approach emphasizes voluntary compliance and innovation enablement. While it currently functions as a soft-law framework—complementing existing guidance such as the AI Business Guidelines issued by the Ministry of Economy, Trade and Industry—it signals the government’s intent to gradually introduce more enforceable measures for high-risk AI applications.

Although the bill does not impose direct obligations on businesses at this stage, companies operating in Japan should closely monitor the implementation of the national AI plan and related guidance, and future development of AI regulations.

Author

Daisuke Tatsuno is a partner in the Firm’s Tokyo office, where he represents leading companies in various intellectual property and information technology matters. He was formerly with the San Francisco office of Baker McKenzie and worked at Warner Bros. Entertainment Inc. Mr. Tatsuno served as speaker on various seminars relating to his field and has authored various publications, including the PLC E-Commerce Practice Manual for the Practical Law Company.

Author

Aya focuses her practice on domestic and global data protection and provides regulatory advice to companies across the telecommunications industry, including platforms, online gaming companies, content businesses, connected car companies and e-commerce businesses. She also advises on licensing agreements, customs procedures and the protection and utilization of intellectual property rights.