Japan. Comprehensive data protection. Act

APPIAct on the Protection of Personal Information (Act No. 57 of 2003)

In force

§1Summary

Synopsis

Japan's general privacy law covering private businesses and, since 2022–23, public bodies. It regulates purpose specification, third-party provision (with opt-out and records), security, breach reporting, retained-data requests and overseas transfers.

Key themes
  • purpose of use
  • third-party provision
  • pseudonymously processed information
  • anonymised information
  • breach reporting
  • overseas transfers
  • extraterritoriality
Unique features

Pseudonymously processed information category allows internal analytics with relaxed purpose rules; overseas transfers need informed consent unless recipient country is whitelisted (EU/UK) or recipient has equivalent systems.

SaaS relevance

Applies to foreign businesses handling personal information of people in Japan in connection with supplying goods or services to them; SaaS processors receiving data under 'entrustment' must be supervised by the client.

§2Obligations

Extraterritorial
Yes
Breach notification
PPC and individuals for prescribed breaches (sensitive data, financial-harm risk, malicious purpose, >1,000 people): preliminary report promptly (c. 3–5 days), full report within 30 days (60 if malicious)
DPO
No
Cross-border transfers
Consent with country information, or whitelisted country (EU/UK), or equivalent-system recipient (e.g. APEC CBPR)
Maximum penalty
Entities up to JPY 100m for violating PPC orders or unlawful database provision (pre-2026)

§3Dates

Key dates
  • Adopted
  • In force
  • Major amendments in force 2017-05-30, 2022-04-01 (2020/2021 amendments), 2023-04-01 (local government); 2026 amendment (Act No. 56 of 2026) promulgated 2026-07-17 – see jp-appi-amendment-2026

§4Text and authority

Text
Authority
Personal Information Protection Commission (PPC)

§5Where it applies

Domestic law of
Japan

§6Sources and verification

Sources consulted
Verification

High confidence.

Breach report day-counts from PPC rules (general knowledge). Mutual EU adequacy since 2019-01-23.