Japan Implements New Transparency Code for Generative AI Intellectual Property

The Japanese government has officially introduced a new set of guiding principles aimed at increasing transparency for generative artificial intelligence developers. Known as the Principles-Code for Protection of Intellectual Property and Transparency for the Appropriate Use of Generative AI, the framework seeks to balance rapid technological innovation with the protection of intellectual property rights. The initiative applies to both domestic companies and international firms that provide AI services to users within Japan. Under the new guidelines, AI operators are encouraged to publicly disclose information regarding the data and methods used to train their models. This includes providing an outline of how they collect information and the measures they take to ensure that copyrighted materials are not misused. The government began accepting formal submissions from companies regarding their compliance with these standards on October 26, 2026. The framework utilizes a comply-or-explain approach, which is common in corporate governance. This means that while the code is not legally binding, companies are expected to either follow the principles or publicly explain their reasons for not doing so. Kimi Onoda, the minister for intellectual property strategy, stated that the government intends to monitor the situation and may consider further measures if necessary to ensure fair practices. One of the primary goals of the code is to address growing concerns among creators that their work is being used for AI training without permission. The guidelines urge developers to respect access restrictions, such as paywalls, and to avoid crawling websites that host pirated content. By establishing clear contact points for rights holders, the government hopes to provide a pathway for creators to verify if their works were included in training datasets. These principles also address the needs of AI users who may want to know if the content they generate could potentially infringe on existing copyrights. The code suggests that operators should establish systems to inform users about the inclusion of copyrighted works in their training data under specific conditions. However, the guidelines also include protections for trade secrets to prevent excessive corporate risk aversion. This initiative follows the enactment of the Act on the Promotion of Research and Development, and Utilization of AI-Related Technology, which came into full effect in September 2025. The new code is designed to function within Japan's existing legal framework rather than imposing strict new penalties. It reflects a broader strategy to foster a safe and secure environment for AI development while maintaining Japan's competitive edge in the global technology market. Beyond intellectual property, the Japanese government is also taking steps to improve the security of AI systems. Recent reports indicate that the government plans to seek earlier access to information regarding undisclosed software vulnerabilities from international AI developers. This move is part of a wider effort to strengthen national defenses against an increasing number of cyberattacks. Meanwhile, the government is also leading by example through its own internal AI initiatives. The Digital Agency has rolled out a generative AI environment called GENAI to all ministries and agencies to improve administrative efficiency. This project involves approximately 180,000 government employees and focuses on using AI to handle back-office tasks like committee management and scheduling. As part of this government-led effort, officials are prioritizing the procurement of AI models that are adapted to Japanese vocabulary and cultural values. By creating stable demand for domestic AI, the government aims to advance Japan's technological autonomy. These efforts are intended to demonstrate the value of trustworthy AI to the public while ensuring that administrative operations remain secure. Looking ahead, the effectiveness of the new transparency code will depend on the willingness of private companies to participate. Many industry observers are watching to see how major global tech firms respond to these voluntary disclosure requests. The government plans to keep a close watch on these developments to ensure that the balance between innovation and rights protection remains stable.