Japan's Human-Centric Approach to AI Regulation

Note: This article represents a practitioner’s interpretation of the relevant rules and regulations in place at the time of writing. I am not a lawyer, and readers should consult with their own legal counsel and compliance teams before taking any action based on this information.

Japan has developed a unique approach to AI regulation that reflects its cultural values and technological aspirations. Unlike the more prescriptive frameworks seen in the EU or China, Japan has chosen to emphasize human-centric principles and international collaboration while maintaining flexibility through soft law mechanisms. This distinctive strategy aligns with Japan’s vision of becoming an “AI-ready society” while ensuring ethical and responsible AI development.

While Japan’s soft law framework doesn’t directly impose binding obligations on US-based AI developers without a Japanese presence, the growing influence of initiatives like the Hiroshima Process makes these principles increasingly relevant globally. US companies targeting the Japanese market or seeking to future-proof their compliance posture should consider adopting Japan’s human-centric approach now: focusing on documentation practices, human oversight, bias testing, and privacy by design, rather than scrambling to comply later as international standards continue to converge.

Current Regulatory Landscape

For years, Japan relied exclusively on a “soft law” approach to AI governance through guidelines and principles. That changed in May 2025, when Japan’s Parliament enacted the Act on Promotion of Research and Development and Utilization of Artificial Intelligence-Related Technologies (commonly called the AI Promotion Act), making it the country’s first law to expressly address AI. Most provisions took effect on June 4, 2025.

That said, the AI Promotion Act is deliberately a “framework law.” It establishes fundamental principles and institutional structures to promote AI development without introducing heavy compliance burdens or penalties for non-compliance. It essentially codifies a duty for AI-utilizing businesses to cooperate with national policies and initiatives. Japan’s stated ambition is to become the “most AI-friendly country” in the world, and the law reflects that priority.

The country’s earlier soft law approach still forms the practical backbone of its AI governance:

Key elements of Japan’s current AI regulatory framework include:

  1. AI Guidelines for Business: Developed by the Ministry of Economy, Trade, and Industry (METI), these guidelines provide principles for AI business actors to incorporate into their products and services.

  2. The Hiroshima Process: Japan has taken a leading role in international AI governance through the Hiroshima Process, which includes the International Code of Conduct for Organizations Developing Advanced AI Systems.

  3. Draft Discussion Points: Japan is considering a more structured approach to AI regulation, potentially including hard law regulations for high-risk AI while maintaining soft law for lower-risk applications.

  4. AI Strategic Headquarters: Established on September 1, 2025, under the AI Promotion Act, this body is chaired by the Prime Minister and composed of Cabinet members. It serves as the central coordination mechanism for national AI policy and strategy.

Human-Centric Principles

The core of Japan’s approach is a set of human-centric principles that guide AI development and deployment. According to the AI Guidelines for Business, these principles include:

  • Human-centric: AI utilization must not infringe upon fundamental human rights guaranteed by the constitution and international standards
  • Safety: AI business actors should avoid damage to lives, bodies, minds, and properties of stakeholders
  • Fairness: Elimination of unfair and harmful bias and discrimination
  • Privacy protection: Respecting and protecting privacy in AI systems
  • Security: Ensuring AI systems are protected from unauthorized manipulations
  • Transparency: Providing stakeholders with necessary information to a reasonable extent
  • Accountability: Ensuring traceability and conforming to guiding principles
  • Education/literacy: Providing education regarding knowledge, literacy, and ethics concerning AI use
  • Fair competition: Maintaining a fair competitive environment for new AI businesses and services
  • Innovation: Promoting innovation and considering interconnectivity and interoperability

These principles reflect Japan’s cultural emphasis on balance, collective responsibility, and harmony between technological advancement and human values.

Implementation Framework

Rather than imposing strict regulatory requirements, Japan’s implementation strategy focuses on practical guidance. Organizations are encouraged to:

  1. Conduct risk assessments: Evaluate both technical and social impacts of AI systems
  2. Implement quality management: Establish robust testing and validation procedures
  3. Maintain documentation: Keep clear records of system development and operation
  4. Protect user interests: Ensure transparency and user control over AI systems

This approach allows organizations to adapt implementation to their specific contexts while still adhering to the core principles.

Risk Categorization Approach

While Japan does not currently classify AI systems according to risk in its guidelines, there are indications that a risk-based approach may be adopted in the future. The Draft Discussion Points suggest a potential classification system that would categorize:

  1. AI developers
  2. AI providers and users

Into “large impact and high risk” and “little impact and low risk” groups, with different regulatory approaches for each category. This would align with global trends toward risk-based AI governance.

Regulatory Oversight

Currently, there is no specific AI regulator in Japan. But several ministries and agencies are engaged in establishing and promoting guidelines regarding AI:

  • The Ministry of Economy, Trade, and Industry (METI)
  • The Ministry of Internal Affairs and Communications
  • The Agency for Cultural Affairs (particularly for copyright issues)
  • The Personal Information Commission

While guidelines from these ministries are not binding law, they are often closely followed by companies and the public in Japan.

International Leadership and Collaboration

Japan has taken a leading role in promoting international cooperation on AI governance, particularly through the Hiroshima AI Process. This initiative demonstrates Japan’s commitment to developing global standards while maintaining space for cultural and regional variations in implementation.

The Hiroshima Principles identify several significant risks that need to be addressed globally, including disinformation, copyright issues, cybersecurity, risks to health and safety, and societal risks such as harmful bias and discrimination.

Future Developments

With the AI Promotion Act now enacted, Japan has moved from pure soft law into a hybrid model. The law itself doesn’t include fines or penalties, but it creates the institutional infrastructure (the AI Strategic Headquarters, an AI Strategy Center) that could serve as the foundation for more binding regulation in the future if the government decides to go that direction.

Discussions continue about how existing laws, particularly the Copyright Act, should address issues concerning rights and harms arising from generative AI. The government’s Fundamental AI Plan is being implemented with the goal of positioning Japan as a global hub for AI development and deployment.

Looking Forward

Success in Japan’s regulatory environment requires understanding both technical requirements and cultural context. Organizations must develop approaches that respect human dignity and autonomy while pursuing technological advancement. This balanced approach offers a model for responsible AI development that could influence global practices.

References

  1. White & Case LLP. (2024). “AI Watch: Global regulatory tracker - Japan.” https://www.whitecase.com/insight-our-thinking/ai-watch-global-regulatory-tracker-japan

  2. Ministry of Economy, Trade and Industry. (2022). “AI Guidelines for Business Version 1.0.” https://www.meti.go.jp/shingikai/mono_info_service/ai_shakai_jisso/pdf/20240419_9.pdf

  3. G7 Hiroshima. (2023). “Hiroshima Process International Code of Conduct for Organizations Developing Advanced AI Systems.” https://www.mofa.go.jp/files/100573473.pdf

  4. Digital Agency of Japan. (2022). “AI Strategy 2022: Becoming an AI-Ready Society.” https://www8.cao.go.jp/cstp/ai/aistratagy2022en.pdf

  5. Future of Privacy Forum. (2025). “Understanding Japan’s AI Promotion Act: An Innovation-First Blueprint for AI Regulation.” https://fpf.org/blog/understanding-japans-ai-promotion-act-an-innovation-first-blueprint-for-ai-regulation/


Changelog

  • February 2026: Updated to reflect Japan’s enactment of the AI Promotion Act (May 2025), the establishment of the AI Strategic Headquarters (September 2025), and the shift from a purely soft-law approach to a hybrid model. Added new reference.