Japan Principles-Code for Protection of Intellectual Property and Transparency for the Appropriate Use of Generative AI
Issued by
Cabinet Office Intellectual Property Strategy Headquarters Secretariat
- September 30, 2026 · Correction — Updated the entry to the final code adopted on 25 August 2026, with its comply-or-explain mechanism and 26 October 2026 notification window (fact-check finding). (Cody Maxwell)
- October 1, 2026 · Correction — Rewrote the practical steps, newsletter hook, search description, and audience fields to match the entry's corrected content. (Cody Maxwell)
Japan's Intellectual Property Strategy Headquarters adopted this code on 25 August 2026, after a draft in December 2025. It asks generative AI developers and providers, including overseas businesses serving Japan, to protect IP and be transparent on a comply-or-explain basis. Notifications open on 26 October 2026.
Applies To
Overview
The code was drafted by the Cabinet Office Intellectual Property Strategy Headquarters Secretariat as part of Japan's broader effort to apply its Intellectual Property (IP) Strategy to generative AI. It is framed as soft law, meaning it does not carry the binding force of statute but is intended to shape industry conduct and may inform future regulation or enforcement posture. The code targets developers who build generative AI models and providers who deploy them to end users, setting expectations around copyright compliance, training data transparency, and output disclosure. Key provisions address how training data is sourced and documented, how rights holders are informed or compensated, and what disclosures must accompany AI-generated content. A public comment period ran from 26 December 2025 to 26 January 2026. The Study Group on IP Rights in the AI Era discussed the final text on 18 August 2026. The Intellectual Property Strategy Headquarters adopted it on 25 August 2026. It works on a comply-or-explain basis: businesses either follow the principles or publicly explain why not. Those accepting it publish a statement and notify the Cabinet Office, with notifications opening on 26 October 2026. Enterprises distributing or deploying generative AI products in Japan should treat compliance with this code as a reputational and pre-regulatory risk management obligation, particularly given Japan's active legislative environment around AI and IP.
Key Requirements
- •Developers and providers of generative AI must implement measures to identify and respect copyrighted works used in model training data.
- •Transparency obligations require disclosure of the general categories or sources of training data to enable rights-holder assessment.
- •AI-generated outputs must be disclosed as such in contexts where misidentification as human-created content could cause harm or confusion.
- •Providers must establish internal processes for receiving and addressing IP infringement claims related to both training data and model outputs.
- •The code works on a comply-or-explain basis: follow it or publicly explain why not, and notify the Cabinet Office from 26 October 2026 if you accept it.
- •No formal penalties are specified under the code, as it is soft law; however, failure to comply may expose organizations to liability under existing Japanese copyright law.
What Your Organization Must Do
- →Decide whether your organization will accept the code or publicly explain why not.
- →Map which generative AI products you build or deploy for users in Japan, including from overseas.
- →Document the general categories and sources of training data so rights holders can assess them.
- →Set up a channel to receive and resolve intellectual property claims about training data and outputs.
- →Label AI-generated outputs where mistaking them for human work could cause harm or confusion.
- →Diarize 26 October 2026, when notifications to the Cabinet Office open for accepting businesses.