Imagine AI detecting cancer in an X-ray or drafting a legal contract for your business. In many countries, these are already becoming reality. But in Japan, regulations written long before AI existed stand in the way, requiring "two or more doctors" for cancer screenings and making AI-generated legal documents potentially illegal. Now the Japanese government is taking an unusual step: asking the public to report which regulations are holding AI back.

Government Asks Citizens to Report AI Barriers

On February 10, 2026, Japan's Cabinet Office, through its Regulatory Reform Promotion Office and AI Strategy Headquarters, launched an unprecedented public solicitation. The government is asking citizens, businesses, and organizations to report specific regulations and systems that hinder AI adoption across all sectors.

The submission window runs through March 10, and the collected cases will feed into discussions at the Regulatory Reform Promotion Council. The findings are expected to shape the "Regulatory Reform Implementation Plan" to be finalized this summer.

This initiative stems from the "Artificial Intelligence Basic Plan" approved by the Cabinet on December 23, 2025. The plan explicitly states that promoting AI adoption, and reforming outdated regulations to enable it, is essential for regional revitalization, economic growth, and improving citizens' quality of life. The government's stance is clear: "not using AI" is the greatest risk Japan faces.

Healthcare: Can AI Replace One of Two Required Doctors?

Japan's municipal cancer screening system currently requires what's called "double reading": two or more doctors must independently examine X-ray images to prevent missed diagnoses. While this system exists for good reason, it's creating serious strain as Japan faces an acute shortage of medical professionals.

Radiologists make up only about 2.2% of all doctors in Japan. In rural areas, the shortage is even more severe. Secondary reading typically requires doctors to travel to a separate facility after their regular clinic hours, adding significant physical and mental burden.

AI medical devices are rapidly emerging as a solution. Several AI diagnostic support systems have already received regulatory approval in Japan, including endoscopy image analysis AI and chest X-ray nodule detection AI. In the 2024 medical fee revision, a new reimbursement of 60 points (roughly $4) was introduced for surgeries assisted by AI lesion detection programs.

The Regulatory Reform Promotion Council is now exploring whether one of the two doctors in the double-reading requirement could be replaced by AI, shifting from "two doctors" to "one doctor plus AI." Formal discussions were scheduled to begin on February 12.

Of course, caution remains. AI relies on training data and may struggle with rare conditions or individual anatomical variations. There's also the risk of "automation bias," with doctors potentially becoming less vigilant when they know AI has already screened the images.

Legal Field: Is AI Contract Drafting Illegal in Japan?

The legal sector faces an even more fundamental challenge. Article 72 of Japan's Attorney Act prohibits anyone without a lawyer's license from handling legal affairs for compensation, a prohibition known as "hi-ben kōi" (unauthorized practice of law). Violations can result in up to two years' imprisonment or fines up to 3 million yen (approximately $20,000).

As AI becomes increasingly capable of drafting and reviewing contracts, even tailoring them to specific circumstances, the question of whether such services constitute unauthorized legal practice has become a major roadblock for the legal technology industry.

In August 2023, Japan's Ministry of Justice issued guidelines outlining three key criteria for determining whether AI-based contract services violate the law:

  • Compensation purpose: Free services generally don't qualify as unauthorized practice
  • Case specificity: Routine contracts without active legal disputes are less likely to violate the law
  • Nature of legal services: Providing general templates (rather than case-specific legal analysis) is less likely to be problematic

However, the guidelines explicitly state they represent only "general principles," with final judgment left to the courts. This ambiguity continues to make businesses hesitant to adopt AI legal tools. Some companies that previously offered paid AI contract review services switched to free models specifically to avoid legal risk.

The Regulatory Reform Council is now examining how far AI-assisted contract creation should be permitted, including possible clarification or amendment of the Attorney Act.

Japan's Position in the Global AI Regulation Landscape

Japan's approach to AI policy occupies a distinctive middle ground internationally. The EU enacted its "EU AI Act" in 2024, implementing a risk-based regulatory framework with strict requirements for high-risk AI applications. The United States, under the Trump administration, has rolled back Biden-era AI executive orders, favoring a deregulatory, innovation-first approach.

Japan chose a third path. The AI Promotion Act (officially: the Act on Promotion of Research, Development and Utilization of AI-Related Technologies), promulgated in June 2025, avoids EU-style hard regulation. Instead, it relies primarily on guidelines and soft law, supplemented by minimal legislative frameworks. An AI Strategy Headquarters was established within the Cabinet, overseeing a Basic AI Plan that is reviewed annually for flexibility.

The current public solicitation exemplifies Japan's "bottom-up" approach to regulatory reform. Rather than imposing changes from above, the government listens to those on the ground who encounter regulatory barriers firsthand.

What's Next: The Summer Implementation Plan

Looking ahead, after the March 10 submission deadline, collected cases will be analyzed and discussed across working groups within the Regulatory Reform Promotion Council. The resulting "Regulatory Reform Implementation Plan," expected this summer, will be formalized through Cabinet approval.

Key focal points include establishing conditions for AI-assisted medical image reading and clarifying the Attorney Act's application to AI legal services. Additionally, the public solicitation may uncover regulatory barriers in sectors that haven't yet received attention: education, finance, construction, agriculture, and beyond.

Japan has entered an era of serious population decline. The "2025 Problem," when all baby boomers turn 75 or older, has intensified the healthcare workforce crisis. Without AI assistance, maintaining basic social infrastructure will become increasingly difficult.

This citizen-driven approach to identifying and removing regulatory barriers could mark a turning point in Japan's AI adoption journey. The question is whether the pace of reform can match the speed of technological change.

In Japan, healthcare and legal regulations are being reconsidered to make room for AI. What regulatory barriers to AI adoption exist in your country? We'd love to hear your perspective!

References