Japan Legal Update

AMT is committed to delivering up-to-date insights on Japanese legal matters to our clients. Our Japan Legal Update provides comprehensive summaries of recent legislative changes, court precedents, and industry trends in Japan across various practice areas. For those seeking more in-depth information, we invite you to explore our newsletter

Recent Regulatory Updates Relevant to Insurance Brokers and Reinsurance

Insurance brokers have long played a pivotal role in the reinsurance market. Foreign insurers without branch offices in Japan are generally prohibited from concluding insurance contracts covering persons domiciled or resident in Japan, property located in Japan, or vessels or aircraft of Japanese nationality. Reinsurance contracts, however, are expressly excepted from this prohibition, and only insurance brokers are permitted to solicit reinsurance contracts to be concluded by such foreign insurers. Consequently, insurance brokers have developed a particular expertise in reinsurance.

Submission to the Diet of the Bill Partially Amending the Financial Instruments and Exchange Act and the Payment Services Act

On April 10, 2026, the Bill for Partially Amending the Financial Instruments and Exchange Act and the Payment Services Act (the "Amendment Bill") was approved by the Cabinet and submitted to the 221st session of the Diet.

Japan’s 2026 Revision of the Customs Act and related laws: Introducing the Anti-Circumvention System for Anti-Dumping Measures

In connection with the 2026 annual revision of the Customs Act and related legislation (the "2026 revision"), Japan has introduced and implemented a new anti-circumvention system (the "System"), which entered into force on April 1, 2026.

Fairness in Transactions Involving IP, Know-How and Data: Recent Reports by the JFTC and the Working Group

On March 11, 2026, the Japan Fair Trade Commission (JFTC) published its Survey Report on Abuse of Superior Bargaining Position Involving IP, Know-How and Data (the "JFTC Report"). On the same day, the Intellectual Property Transaction Fairness Working Group also issued a separate report on the fair and proper treatment of intellectual property transactions (the "Working Group Report"). Under Article 2, Paragraph 9, Item 5 of the Antimonopoly Act, abuse of a superior bargaining position refers to certain types of conduct in which a party unjustly exploits its superior bargaining position vis-à-vis a counterparty, contrary to normal business practices.

Summary of the Public Comments on the Institutional Design of Japan’s Emissions Trading Scheme (GX-ETS)

As of April 1, 2026, Japan’s Emissions Trading Scheme (GX-ETS), a mandatory scheme similar to the European Union Emissions Trading System (EU ETS), has been fully implemented. On March 30, 2026, the results of the public comments on the draft amendment to the Ordinance for Enforcement of the Act on Promotion of Smooth Transition to a Decarbonized Growth-Oriented Economic Structure, which sets out the detailed design of the GX-ETS, were published. The public comments and the results of the comments submission process are important for understanding the direction of the system’s practical implementation.

The FEFTA Amendment Bill Regarding Inward Direct Investment

On March 17, 2026, the bill for Japan’s proposed overhaul of the Foreign Exchange and Foreign Trade Act (FEFTA) was submitted to the Diet (the "Bill").