Japan — AI × Entertainment Regulation¶

⚠️ Not legal advice. → Comparison by country / Cross-cutting overview (Japanese) Japanese edition: ../../../ethics-legal/by-country/japan.md

Training¶

Copyright Act Article 30-4: uses not aimed at "enjoying" the thoughts or sentiments expressed in a work, such as data analysis, are permitted without permission under certain conditions
Exception: where it would "unreasonably prejudice the interests of the copyright owner"
Agency for Cultural Affairs, "General Understanding on AI and Copyright" (2024): additional training intended to deliberately imitate or output a specific creator's works may fall outside the provision, because an "enjoyment" purpose coexists

Infringement is possible where an output is similar to an existing work and relied on it (the usual test)
Without human creative contribution, AI outputs are unlikely to be recognized as copyrighted works
Example: In October 2025, after large numbers of videos resembling Japanese anime were made with the video generator Sora 2, the Japanese government asked OpenAI not to infringe copyrights, and CODA sent a written request asking, among other things, that it not train without permission (→ case A05)

On August 7, 2026, a Ministry of Justice study group published its interpretive guideline on right-of-publicity infringement by generative AI.

Voice, like likeness, is covered by the right of publicity and the right not to be used without good reason
Test: cases "aimed solely at exploiting customer-attracting power," such as the three categories from the Supreme Court's Pink Lady decision: (1) making the voice itself a product to be enjoyed, (2) attaching it to differentiate a product, (3) using it in advertising
Even a similar voice counts as "use of the person's voice" if, considering the degree of similarity and information that brings the person to mind, customers can identify it as that person's voice
Examples of infringement: voice messages, voice stickers, audiobooks, AI covers, narration, alarm clocks, car navigation, smart speakers, advertising
Voice actors: it is enough that the voice itself has power to drive sales; the name or face need not be widely known
Character voices that are not a real person's voice are out of scope
Human impressions and voice mimicry do not infringe unless they cause confusion with the person
Intellectual Property Strategic Program 2026: consideration continues, including amending the Unfair Competition Prevention Act

Gacha: the Act against Unjustifiable Premiums and Misleading Representations ("complete gacha" ban) and industry self-regulation
AI companions and AI labeling: no dedicated legal duties as of September 2026
Personal data: Act on the Protection of Personal Information (conversation logs, memory data)

💡 Do not rely on "Japan is lenient on training" alone. Rights holders, the government, and the guideline are all becoming stricter on outputs resembling specific works and on voice
For AI voices, use either "a licensed real voice" or "a voice that does not imitate a real person" (→ ai-characters P38)

Ministry of Justice, report of the study group on civil liability for unauthorized use of likeness, voice, etc. (Japanese) https://www.moj.go.jp/content/001468286.pdf
CODA, request to OpenAI regarding Sora 2 (Japanese) https://coda-cj.jp/news/2577/
ITmedia NEWS, the Japanese government's request (Japanese) https://www.itmedia.co.jp/news/articles/2510/10/news115.html