JAPAN Law and Practice Contributed by: Yutaro Fujimoto, Yurika Masakane, Hirokazu Tanaka and Yutaro Kato, Nagashima Ohno & Tsunematsu
to provide loans required for large-scale transmission line and power generation facilities. Also, the 2026 Amendment establishes new electricity markets to meet power needs in the medium-to-long term (see 1.7 Announcements Regarding New Policies ). Changes to the Renewable Energy Special Measures Act The Act on Special Measures Concerning Procure- ment of Electricity from Renewable Energy Sources by Electricity Utilities (Act No 108 of 2011, as amended – the “Renewable Energy Special Measures Act”), promulgated in 2011, introduced the FIT Regime. Under the Renewable Energy Special Measures Act, renewable energy that meets statutory and regulatory requirements is sold at a fixed price for a specified number of years (20 years, in many cases) to trans- mission and distribution network operators. In order to promote investment in renewable energy, the feed-in tariff – that is, the price of renewable energy – is set at a rate generally higher than the market rate. On 5 June 2020, the Diet passed a Bill to amend the Renewable Energy Special Measures Act (the “2022 Amendment”). In order to harmonise the renewable energy market with the conventional energy market, the 2022 Amendment introduced the FIP Regime from 1 April 2022 to complement the existing FIT Regime. The FIP Regime grants to renewable energy genera- tors the balance obtained from subtracting the refer- ence market rate price of supplied electricity from a fixed rate (which will generally be set higher than the market rate), assuming that the generators will sell their electricity to the market. Under the FIP Regime, renewable energy generators will need to manage, to a certain extent, the volatility risks of the market price and the off-taker’s credit risks of the energy they gen- erate. Moreover, under the FIP Regime, as with con- ventional power plant operators, renewable energy generators need to manage their imbalance risks. Under the FIT Regime and FIP Regime, the introduc- tion of renewable power generation facilities has been significantly growing and many new companies have entered the renewable energy market. However, since power generation facilities have a significant impact on the local community and environment where they are installed, there have been growing concerns in
local communities regarding safety, and the potential impact on the landscape and environment. To promote the introduction of renewable power generation facili- ties in a sustainable manner, harmonisation between renewable energy projects and the local community is important. As such, in May 2023, the Diet passed a Bill to amend the Renewable Energy Special Meas- ures Act (the “2024 Amendment of Renewable Energy Special Measures Act”), which came into force on 1 April 2024. Under the 2024 Amendment of Renewable Energy Special Measures Act, renewable energy pro- ject operators are required to hold briefing sessions with local communities in compliance with detailed requirements if such operators obtain initial approval under the FIT Regime or FIP Regime (ie, before they commence operating their renewable energy facilities) or if they change the ownership structure of the pro- ject in any material respect. Further, in December 2025, the government announced the Mega Solar Power Plant Countermeasures Pack- age to strengthen regulations on mega solar projects. The three key elements of this package are (i) strength- ening regulations against inappropriate projects; (ii) enhancing co-ordination with local communities; and (iii) focusing financial support on specific appropriate projects rather than providing general support, includ- ing terminating support for the FIT Regime and FIP Regime for new mega-solar projects from FY 2027, and the government is steadily moving forward with the implementation of this package. Change to Bidding Rules Under the Offshore Wind Promotion Act In order to promote offshore wind electricity genera- tion in Japan in the general sea area (rather than in port and harbour areas), the Diet passed the Act for the Promotion of Use of Marine Areas for Develop- ment of Marine Renewable Energy Generation Facili- ties (Act No 89 of 2018, as amended – the “Offshore Wind Promotion Act”). At the time of publication of this guide, public bidding for the first to third general sea area batches had been conducted. In order to promote offshore wind power generation further, the government submitted a Bill to the Diet in March 2025 to expand the promoted areas to include
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