Japan AI Promotion Act

Article 7 defines a “utilisation business” as a person intending to develop or supply products or services using AI-related technologies, or otherwise to use such technologies in business activities. It requires them to endeavour, in line with the basic principles, to make their operations more efficient and advanced and to create new industries through active use of AI, and to cooperate with measures implemented by the State under Art. 4 and by local governments under Art. 5. This is a responsibility clause, not a sanctionable duty; in practice it means responding to government surveys, taking part in guideline and standards development, and answering requests for information.

Applies when

Businesses that develop, supply or use AI products and services in Japan, including Chinese AI companies with a Japanese presence.

Evidence to retain

• · Correspondence records of cooperation with government surveys and information requests
• · Records of participation in guideline or standards development
• · Internal AI utilisation policy document

Estimated first-time effort: 1–3 person-days (estimate, not a commitment)

Article 13 requires the State to develop guidelines consistent with international norms, and take other necessary measures, to ensure the appropriate conduct of AI research, development and use; Article 18 requires the government to adopt an AI Basic Plan. Companies should treat both as the baseline governance expectation for the Japanese market, fold them into their internal AI governance, and answer against them in public procurement and large-customer due diligence. The AI Basic Plan was adopted by Cabinet decision on 23 December 2025.

Applies when

Chinese companies selling AI products to Japanese government bodies or large enterprise customers.

Evidence to retain

• · Mapping table between internal AI governance policy and the State guidelines
• · Tracking record of Basic Plan measures relevant to the business
• · Working papers for due-diligence questionnaire responses

Estimated first-time effort: 2–6 person-days (estimate, not a commitment)

Because the Act creates no penalties, approvals or filings, AI compliance in Japan must be assessed under existing law: the APPI (including the 2026 amendment), the Copyright Act (training and outputs), the Unfair Competition Prevention Act, product liability law, and sectoral regulation in finance, healthcare, automotive and telecommunications. Internally, companies should maintain an explicit mapping recording that the Japanese AI Act creates no standalone duties while the relevant duties sit in other statutes, so that the Act is not mistaken for a compliance clearance.

Applies when

All Chinese companies doing AI business in Japan, especially teams making market decisions on the premise that Japan has no dedicated AI regulation.

Evidence to retain

• · Mapping of Japanese AI-relevant legal duties to statutes and owning functions
• · Compliance status assessment under each applicable statute
• · Legal-change monitoring mechanism and review records

Estimated first-time effort: 3–8 person-days (estimate, not a commitment)