The Japan Association of New Economy (JANE; Location: Minato-ku, Tokyo; Representative Director: Mickey Mikitani) issues the following statement regarding the Cabinet Decision dated April 7, 2026 approving the bill to amend the Act on the Protection of Personal Information.

April 14, 2026
Japan Association of New Economy (JANE)
Representative Director
Mickey Mikitani 

1. Views on the Cabinet-Approved Bill
Throughout the review discussions concerning the revision of the Act on the Protection of Personal Information, JANE has consistently argued that data utilization is vital for
Japan’s industrial competitiveness. We have maintained that, in order to promote the effective use of data while striking a balance between protection and utilization, it is essential to design systems grounded in actual business practices and to engage in continuous dialogue with stakeholders. Furthermore, we have expressed serious concern that introducing a surcharge system risks deterring compliant businesses and impeding the beneficial use of data.

Based on our review of the Cabinet-approved bill, we acknowledge that the Cabinet-approved bill reflects certain revisions in light of various opinions submitted, compared to the “Policy for Institutional Revision of the Act on the Protection of Personal Information: So-called Triennial Review” published by the Personal Information Protection Commission in March of last year. Nevertheless, we continue to have concerns that numerous provisions remain that may have an excessive chilling effect on economic activity.

2. Concerns That Could Have a Significant Impact on Actual Business Practices
The impact of these amendments on actual business practices will vary greatly depending on how matters are stipulated in future Cabinet Orders and Committee Rules, as well as the interpretations provided in guidelines and Q&As. We are also concerned about the future direction of enforcement policies, which have lacked transparency to date.

We hold particularly strong concerns regarding the following matters because their interpretation and guiding principles remain unclear:

• Detailed requirements for the exception to consent obligations in the context of statistical compilation and similar activities.
• The scope of cases in which it is evident—based on the circumstances of collection—that the rights and interests of the data subject, including those under 16, are not harmed because the processing is not contrary to their wishes.
• Appropriate approaches to obtaining consent from legal guardians of data subjects under 16 as well as exceptions to such consent requirements and notification procedures.
• Specific definitions of improper use and fraudulent acquisition regarding “contactable personal-related information” particularly in relation to cookie data.
• The scope of the following cases listed as acts and incidents subject to surcharges:

– Cases in which a business operator handling personal information has failed to exercise due care to prevent the relevant acts
– Cases in which the rights or interests of an individual have been infringed upon or a specific risk of infringement has arisen

• Specific details regarding the rationalization of breach reporting obligations and notification to data subjects.

3. Requests for the Formulation and Operation of Subordinate Legislations
While official recommendations and orders have been limited to date, vague and opaque expressions such as “malicious” and “improper” have been used throughout the review discussions. To promote sound data utilization and foster a shared understanding among stakeholders, it is essential to improve the transparency of future enforcement policies and conduct a thorough analysis of the current state of affairs.

JANE strongly hopes that in the formulation of future Cabinet Orders, Committee Rules, guidelines and Q&As, the government conducts careful and thorough communication with stakeholders in advance. It is vital that these measures are grounded in the realities of actual business practices.