JAPAN Law and Practice Contributed by: Hiroshi Mitoma, Tomohiko Iwasaki, Kosuke Hamaguchi and Akira Komatsu, Nagashima Ohno & Tsunematsu
net, and analysis and investigation into infringement of citizens’ rights and interests are conducted by the Cabinet Office. Based on the results of investigations, the Cabinet Office may provide guidance, advice and information, and take other necessary measures. 8.4 Key Disclosure Requirements for AI Use At present, no disclosure obligations are imposed on companies with respect to AI-use, strategy and gov - ernance. Although not legally binding, the Guidelines provide that, from the perspective of transparency, companies should endeavour to provide information such as data collection methods, training methods,
and information relating to foundation models. The Cabinet Office is currently deliberating on the formu - lation of the Generative AI Principles and Code. The draft Generative AI Principles and Code, as released for public comment, provides principles for ensur - ing transparency and protecting intellectual property rights, and requests that generative AI developers and providers disclose information relating to models used, training data, accountability, and the status of measures taken to protect intellectual property rights. The public comment period closed on 26 January 2026 but the Generative AI Principles and Code have not yet been formally finalised.
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