Japan's AI Governance: Major Government Steps Since the AI Act

Written By

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Aya Saito

Partner
Japan

I am a commercial technology lawyer based in Japan, specialising in complex transactions and strategic legal support for clients leveraging technology to drive growth and innovation globally. My approach is to provide pragmatic, business-focused advice that helps clients navigate legal complexities while achieving their commercial objectives.

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Masahiro Tanabe

Partner
Japan

I am a corporate partner based in Tokyo who helps clients navigate the global energy transition. I regularly advise clients on their complex renewable energy projects in Japan and globally.

Introduction

In May of this year, Japan enacted the AI Act (Act on Promotion of Research and Development, and Utilisation of AI-related Technology), which came into full effect on 1 September 2025. Unlike the EU AI Act, Japan's AI Act is a principle-based framework that does not impose specific obligations or penalties in relation to the use of AI. Instead, the Act aims to establish that the research, development and use of AI is a national priority. You can read more about Japan's AI Act and its comparison to the EU AI Act here.

Since the enactment, the Japanese government has taken swift action under the Act. This article provides an overview of these critical developments, as well as what can be expected to come. 

Establishment of the AI Strategic Headquarters

Under the AI Act, the AI Strategic Headquarters—a central coordinating body for national AI policy and implementation – was established on 1 September 2025. The Headquarters is led by the Prime Minister and includes all Ministers as its members. Additionally, a Minister of State for Artificial Intelligence Strategy was appointed to support the Headquarters' work. The Headquarters functions as the “control tower” for AI policy, responsible for the comprehensive and systematic advancement of policies that promote AI research, development, and utilisation.

Draft AI Basic Plan

A primary responsibility of the AI Strategic Headquarters is developing the AI Basic Plan, which outlines government measures to promote AI research, development, and utilisation. A draft outline of the AI Basic Plan was published on 12 September 2025. The draft's core concept focuses on leveraging AI to drive economic development and create a safe, secure society, positioning Japan as the world's most AI-friendly nation. The plan's underlying principle emphasises balancing innovation with risk management in AI advancement. The draft also addresses Japan's leadership role in international AI governance dialogue and the need for regulatory agility to match technological advancement.

Guidelines for appropriate AI use

Although the AI Act imposes no penalties, it mandates appropriate AI use and requires the government to implement supporting measures, including guidelines based on international standards. An expert panel under the AI Strategic Headquarters is developing comprehensive guidelines for appropriate AI use across both public and private sectors, with completion targeted for the end of 2025. These guidelines aim to foster an environment of trust and responsible AI adoption, providing guidance for AI developers, providers, and the general public.

Government studies on AI use

To effectively promote innovation while managing AI risks, the government must conduct comprehensive analysis of current AI research, development, and utilisation. Alongside the AI Basic Plan draft, the government released findings from studies examining the societal impact of deepfake pornography and AI applications in HR processes and recruitment. These studies, commissioned before the AI Strategic Headquarters' establishment, demonstrate the government's proactive commitment to AI advancement. Building on these findings and expert panel discussions, additional studies are planned covering AI business applications, development safety measures, and AI-related rights violations.

Japan’s new leader

On 4 October 2025, Sanae Takaichi was elected leader of Japan’s ruling party, the Liberal Democratic Party (LDP). Takaichi is anticipated to become the next Prime Minister of Japan upon election in Parliament on 15 October 2025. Takaichi has identified AI as a critical technology and key investment areas for Japan’s long-term international competitiveness, particularly from economic security perspective. Besides this, she has not articulated detailed AI policies in the recent LDP election and her broader approach on how she addresses innovation and risk for AI more generally remains to be seen.

Conclusion

Until now, the Japanese government has kept up a fast pace in its actions post-enactment of the AI Act, demonstrating its desire to expedite the practical implementation of the Act.  Moving forward, leadership direction and coordination among Ministries will be crucial in determining whether Japan achieves its ambition to become the world's most AI-friendly nation. The AI Strategic Headquarters warrants close monitoring, with the end of 2025 representing a critical milestone for AI Basic Plan adoption and finalisation of the appropriate use guidelines. Continued monitoring of these developments will be essential for navigating Japan's evolving AI governance landscape and maintaining compliant, ethical, and competitive business operations.

 

For more information, please contact Aya Saito and Masahiro Tanabe.

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