On March 10, 2026, the Japan Association of New Economy (JANE) submitted comments in response to the Cabinet Office’s ”Request for Information on Regulations and Systems That Pose Obstacles or Produce Insufficient Effects in the Social Implementation of AI.”

[Summary of Comments]

1. Clarification of the Relationship with Existing Industry-Specific Laws and New Guidelines (Soft Law), and Review of Applicable Rules
   Concerns over potential conflicts with existing industry-specific laws — such as the Attorney Act and the Financial Instruments and Exchange Act — when AI performs specialized tasks in legal, tax, and labor affairs, or provides recommendations on financial products and insurance, have become a barrier to AI adoption. In response, JANE calls for the clarification of the legality of AI use under conditions such as explicitly stipulating that final decisions and responsibility rest with the user, as well as the establishment of special exemption frameworks under existing laws that are adapted to the current era.

2. Clarification of Interpretation and Flexibility of Requirements under the Act on the Protection of Personal Information etc.
   In AI development and data collaboration, ambiguities in the interpretation of the Act on the Protection of Personal Information and the strictness of its requirements are causing a chilling effect on business activities. Specifically, JANE calls for greater flexibility and clarity in the frameworks for “joint use,” “improvement of public health,” and “statistical compilation” when utilizing care-related data. Furthermore, JANE calls on the government and relevant authorities to provide clear official positions and practical reference examples regarding the handling of third-party provision and cross-border transfer of personal information when utilizing overseas general-purpose generative AI services via API integration, as well as the legality of SaaS vendors using customer input data for AI training.

In addition, JANE resubmitted, as part of this call for information, the comments it had previously submitted to the Cabinet Office on January 26, 2026, regarding the “Comments on the Cabinet Office’s Draft “Principles and Code on the Protection of Intellectual Property and Transparency for the Appropriate Use of Generative AI (tentative title)“, given that these comments may also have a significant impact on future AI policy.

*For the full text of the submitted comments, please click here.  (in Japanese only)