2025.12.19

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

Policy Advocacy Advocacy

On December 11, 2025, the Japan Association of New Economy (JANE. Location: Minato-ku, Tokyo; Representative Director: Mickey Mikitani) submitted its comments regarding the “Draft 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】

1. Securing Procedural Propriety and Sufficient Period
· Although collaboration with the industry is indispensable, given that these guidelines are based on the premise of “voluntary efforts,” the period for public consultation was as short as approximately one week, making it impossible to sufficiently reflect the voices of the industry.

· We request the implementation of appropriate procedures that enable the submission of accurate comments, such as setting a sufficient period of approximately one month, clarifying the process of changing and specifying the “Outline of the Guidelines” into the “Draft Guidelines,” and resolving footnotes that lack specific descriptions.
 
2. Introduction and Requirements of the Latest Security Technologies
· Given the current situation where AI handles vast amounts of confidential information and cyberattacks are becoming increasingly diverse and sophisticated, we strongly request that the descriptions of “security” and “securing sufficient safety” be revised to state that efforts will be made to reduce risks by utilizing the latest security technologies and expertise.
 
· This is to address the risk of highly confidential information leakage, and it is necessary to mention the latest technologies from the perspective of the EU AI Act, as well as from the perspective of leading the Hiroshima AI Process (HAIP) and promoting international coordination.

3. Introduction of the Latest Privacy Protection Measures and International Coordination
· In response to privacy concerns accompanying the development of AI, we request that the description of “privacy” be revised to “appropriate protection through technical means such as the latest privacy protection measures according to the importance of the data handled.”
 
· As the practical application of Privacy-Enhancing Technologies (PETs) progresses internationally and the EU AI Act requires the latest protection measures for high-risk AI, it is indispensable to mention the latest privacy protection measures from the standpoint of leading the HAIP.
 
4. Balance Between Innovation Promotion and Risk Management
· Excessive regulations and strict procedural requirements in the name of securing propriety carry the risk of substantially hindering emerging research and development.
 
· Given that the AI Act also aims to promote research and development, we request that the balance between risk management and innovation promotion be prioritized in the implementation of the guidelines, with consideration for flexibility to tolerate moderate failures in early-stage exploratory activities. Furthermore, to encourage active utilization, the requirements imposed on business providers should be reduced.
 
5. Development of Technical Foundations to Provide Peace of Mind for Data Holders and Promotion of Self-Data Utilization
· In order to secure high-quality data and utilize it appropriately, AI development and business providers should strive to develop privacy and security foundations that allow data holders to provide data with peace of mind.
 
· Furthermore, in order to enable citizens and business operators to utilize AI optimized for their own needs, the national and local governments should, under their own responsibility, develop an environment where self-data in fields such as medical and finance can be collected and linked in a secure and machine-friendly manner through APIs and other means.

Please click here for the full text of the submitted comments. (Japanese only)
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