The tracker · Japan
Japan’s voluntary due diligence guidelines, increasingly hard-edged through procurement and buyer cascades.
Revised National Action Plan, in effect from April 2026, makes human rights due diligence a priority area; the guidelines remain voluntary.
In plain language
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. The revised National Action Plan published in December 2025 names human rights due diligence as a priority area for the first time, but it stops short of legislation. 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
Companies are expected to identify, prevent, mitigate and account for adverse human rights impacts across supply chains.
Grievance mechanisms and public disclosure of due diligence efforts are expected under the guidelines.
Timeline
Japan adopted its National Action Plan on business and human rights.
METI published the due diligence guidelines.
Public procurement linkage introduced and binding options studied.
Government published the revised National Action Plan, making human rights due diligence and support for small and medium enterprises priority areas.
Implementation of the revised National Action Plan began.
Changelog
Added the revised National Action Plan published in December 2025 and in effect from April 2026.
Study group progress and procurement linkage developments recorded.