Is compliance with the code mandatory?

No. The government uses a "comply or explain" approach, allowing generative AI businesses to choose either to comply with the code or publicly explain why they will not comply.

What must firms disclose under the code?

The code requires businesses to disclose the generative AI models they use, their training data, and methods for collecting such data on their websites, though disclosure of sensitive information will not be mandatory. Firms must also disclose whether certain webpages are included in training data when requested by copyright holders, and respond to information requests from users concerned about infringement.

Does the code apply to foreign AI companies?

Yes. Foreign businesses providing AI services in Japan will also be covered by the "comply or explain" approach.

AI Safety & AlignmentAI Regulation & PolicyJapan Times TechAug 19, 2026Aug 19, 2026, 16:01 JST

Japan to require AI firms disclose training data under new code

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3 Key Points

What happened
Japan's government panel approved a voluntary "principle code" requiring generative AI businesses to disclose their AI models, training data, and data collection methods on their websites. The code applies to both domestic and foreign firms providing AI services in Japan and uses a "comply or explain" approach, meaning companies can either follow the code or publicly state why they will not.
Why it matters
The code addresses growing concerns that AI models are being trained on texts and images without consent, potentially infringing copyrights. It balances intellectual property protection with technological innovation by building on a law on AI-related technology enacted in May 2025. Firms complying with the code must announce their compliance on their websites and notify the government.
What to watch
The code contains three principles—disclosure of AI models and training data methods; disclosure of whether specific webpages were included in training data when copyright holders request it; and responsiveness to information requests from users concerned about infringement. Disclosure of sensitive information will not be mandatory.

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Context & Analysis

The code responds to a concrete problem: as generative AI has grown increasingly popular, concerns have mounted that texts and images are being used to train AI models without consent, potentially infringing copyrights. The government framed this initiative as a way to balance rights protection with technological innovation, anchoring it in a law on AI-related technology enacted in May 2025. Rather than imposing binding rules, the "comply or explain" approach gives businesses flexibility while creating transparency—companies that choose not to comply must publicly justify that decision, creating reputational incentive toward disclosure. The three principles layer transparency in stages: first, broad disclosure of models and methods; second, targeted disclosure when copyright holders suspect infringement; and third, responsiveness to user concerns. By extending the code to foreign providers, Japan signals its intent to shape global AI practices affecting its market.

FAQ

Is compliance with the code mandatory?: No. The government uses a "comply or explain" approach, allowing generative AI businesses to choose either to comply with the code or publicly explain why they will not comply.
What must firms disclose under the code?: The code requires businesses to disclose the generative AI models they use, their training data, and methods for collecting such data on their websites, though disclosure of sensitive information will not be mandatory. Firms must also disclose whether certain webpages are included in training data when requested by copyright holders, and respond to information requests from users concerned about infringement.
Does the code apply to foreign AI companies?: Yes. Foreign businesses providing AI services in Japan will also be covered by the "comply or explain" approach.

Japan Times TechRead Original Article

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Also reported by Hacker News

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