The tracker · Japan

Japan METI Guidelines on Human Rights Due Diligence

Voluntary Japan Entry updated February 2026

Japan’s voluntary due diligence guidelines, increasingly hard-edged through procurement and buyer cascades.

StatusVoluntary
EnactedSeptember 2022 (guidelines published)
First compliance deadlineNot applicable (voluntary)
Companies in scopeAll companies operating in Japan, on a voluntary basis
Maximum penaltyNone; reputational and procurement consequences only
Civil liabilityNone
Enforcement bodyNone; METI stewardship with public procurement linkage

Latest movement

Government study on binding options continues; procurement-linked expectations doing the practical work.

In plain language

What this law does

The METI guidelines set out UNGP-aligned expectations for human rights due diligence by companies operating in Japan, covering policy commitments, impact identification, prevention and mitigation, remedy and disclosure. They carry no penalties, but linkage to public procurement and the compliance programmes of the large trading houses gives them practical force.

The open question tracked here is whether Japan moves from guidance to statute. Government study groups continue to examine binding options, while Japanese buyers increasingly transmit due diligence requirements to Asian suppliers through contracts, making the guidelines a de facto regional standard whose operational mechanisms are still developing.

Obligations

What it asks of companies

  1. UNGP-aligned due diligence (voluntary)

    Companies are expected to identify, prevent, mitigate and account for adverse human rights impacts across supply chains.

  2. Remedy and disclosure (voluntary)

    Grievance mechanisms and public disclosure of due diligence efforts are expected under the guidelines.

Timeline

How it got here

October 2020

Japan adopted its National Action Plan on business and human rights.

September 2022

METI published the due diligence guidelines.

2023 onwards

Public procurement linkage introduced and binding options studied.

Changelog

Entry history

February 2026

Study group progress and procurement linkage developments recorded.

Sources

Primary documents