2025.12.19

【Public Consultation】Submission of Comments on the “Draft Outline of the AI Outline of the AI Basic Plan and the Draft Outline of Guidelines for Ensuring the Appropriateness of Research, Development and Utilization of AI-Related Technologies”

Policy Advocacy Advocacy
 
On November 27, 2025, the Japan Association of New Economy (JANE. Location: Minato-ku, Tokyo; Representative Director: Mickey Mikitani) submitted its comments regarding “Outline of the AI Basic Plan” and the “Outline of the Guidelines for Ensuring the Appropriateness of Research, Development and Utilization of AI -Related Technologies” for which the AI Policy Promotion Office, Secretariat of Science, Technology and Innovation Policy, Cabinet Office invited public consultation.
 
【Summary of Comments on the Draft Outline of the AI Basic Plan】
 
1. Explicit Expression of a Strong Sense of Crisis Regarding International Competition and Securing a Period for Public Consultation
· The plan as a whole should demonstrate a strong sense of crisis as a nation, stating that Japan will lose the cloud competition, and there is a high likelihood that it will also lose in international competition regarding AI if things continue as they are.
 
· Additionally, to broadly reflect the voices of the industry, we strongly request that a sufficient period, such as one month, be secured for public consultation—rather than a short period (approximately one week) as in the current public consultation.
 
2. Specific Review of Regulations such as the Acts on Professionals
· In professional fields such as legal and medical, it should be clearly stated that the approach to regulations, such as the Acts on Professionals, will be reviewed on the premise of the social implementation of generative AI.
 
· There is a concern that regulations that do not adapt to AI will stifle the development of domestic companies and hinder Japan’s AI innovation and international competitiveness.
 
3. Establishment of specific policies regarding data linkage and sharing
· Specific objectives, benefits, and assumptions regarding shared data should be presented for data sharing across the public and private sectors as well as between companies.
 
· Furthermore, we strongly request that specific operational policies be clearly stated, not only for security but also for data storage locations, access rights, and data linkage foundations.
 
4. Intensive Investment Strategy through the Combination of Japan’s Areas of Strength and AI
· Full-scale competition with other countries in AI foundational technologies is not realistic; Japan’s path to victory lies in combining AI with existing areas of strength, such as manufacturing and robotics.
 
· Instead of protecting domestic industries, intensive investment should be prioritized for creating Japan’s unique value-add that can be deployed in the global market.
 
5. Support for the Utilization of Technologies that Enhance Safety (such as Confidential Computing)
· In order to respond to the risks of AI, the development of technical measures such as data security should be promoted.
 
· We expect the government to proactively provide information on specific safety-enhancing technologies, such as confidential computing, which enables data encryption during computation.
 
【Summary of Comments on the Draft Outline for Guidelines of Ensuring the Appropriateness of Research, Development and Utilization of AI-Related Technologies】
 
1. Securing a Period for Public Consultation
· This outline of the guidelines represents a critical policy that requires the indispensable involvement of private companies and close collaboration with industry.
 
· Since the period for public consultation was as short as approximately one week, we request that a sufficient period, such as one month, be provided to broadly reflect the voices of the industry.
 
2. Clarification of Coordination with Existing Governance Processes
· Since business operators consider AI elements by incorporating them into existing governance processes, the descriptions in the guidelines should be based on the premise of utilizing them with an understanding of existing processes.
 
· We request that the phrasing be revised to reflect the addition of AI-specific matters while initiating new efforts as necessary.
 
3. Consideration of Whether Efforts to Ensure Transparency may Result in Excessive Regulation
· While securing transparency is important, consideration should be made to ensure that its specific details do not become barriers to the voluntary and proactive efforts of business operators or result in excessive regulation.
 
· We strongly request that opportunities be provided to broadly hear the voices of the industry during consideration.
 
4. Traslating “consideration” regarding data into concrete actions
· Since the term “consideration” in “consideration for stakeholders” is ambiguous, we request phrasing that can be translated into concrete actions by business operators.
 
· For example, it should be revised to expressions that indicate more concrete actions, such as “providing information within a reasonable scope.”
 
5. Addition of Items for Strengthening Development Infrastructure and Human Resource Development Corresponding to the AI Basic Plan
· Items corresponding to the “Strengthening and Securing of Infrastructure for AI Development and Utilization” and “Development and Securing of AI Human Resources” found in the Draft Outline of the AI Basic Plan are not identified in the outline of these guidelines.
 
· From the perspective of continuity, concrete action items regarding investment in energy policies and government-led human resource development should be added.
 
Please click here for the full text of the submitted comments. (Japanese only)
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