Introduction
In today’s global economy, the responsibility of business enterprises is no longer assessed solely in terms of profitability, job creation, or their contribution to economic growth. The way companies address workers’ rights, the conditions under which suppliers operate, discrimination, exploitation, privacy, the impacts of emerging technologies, and access to remedy for victims has also become part of the assessment of their economic performance. The expansion of cross-border supply chains means that the human rights consequences of a business decision do not necessarily materialize in the same country in which the company is based, turning corporate accountability into an issue that extends beyond national borders. Against this backdrop, “business and human rights” has become an important field of contemporary economic governance, while the concept of “human rights due diligence” has gradually moved to the center of government policymaking and expectations placed on companies.
In this context, National Action Plans on Business and Human Rights have become one of the principal tools through which governments translate broad international principles into national-level policies and measures. The significance of these plans lies not merely in declaring a commitment to respect human rights, but in the extent to which they can influence corporate conduct, supply chains, public procurement, oversight mechanisms, and victims’ access to effective remedy. Given the prominent position of Japanese companies within production and trade networks across Asia and globally, Japan provides an important case for examining this transformation. The revision of Japan’s National Action Plan on Business and Human Rights can be viewed within the broader context of efforts to reconcile economic competitiveness with the growing requirements of corporate accountability, human rights due diligence, and protection for vulnerable groups. Despite significant progress, however, this effort continues to raise serious questions regarding the adequacy of voluntary mechanisms, the extent to which corporate commitments are legally binding, and the effectiveness of monitoring and remedial mechanisms.
Incidents
On 24 December 2025, Japan approved the revised version of its “National Action Plan on Business and Human Rights,” a policy document designed to strengthen respect for human rights in business activities and coordinate the measures undertaken by government agencies. The Plan was developed in line with Japan’s domestic policies and within the framework of the United Nations Guiding Principles on Business and Human Rights. According to information published by the Office of the United Nations High Commissioner for Human Rights, more than 35 countries, including Germany, Indonesia, Belgium, Argentina, Denmark, Finland, France, the Netherlands, Norway, Pakistan, Spain, and others, have so far adopted a National Action Plan on Business and Human Rights, with Japan among them[1]. For example, in the Netherlands, the revised National Action Plan was published by the government in 2022 and submitted to the House of Representatives, covering the implementation period from 2022 to 2026[2]. Pakistan also adopted its first National Action Plan in September 2021. Covering the period from 2021 to 2026, the Plan is built around three pillars: the State duty to protect human rights, the corporate responsibility to respect human rights, and access to remedy. It also places emphasis on equality and gender considerations among its priority areas[3].
Against this backdrop, Japan, during its G7 Presidency in 2023, responsibly advanced discussions on sustainable supply chains in alignment with the United Nations Guiding Principles on Business and Human Rights and strengthened related commitments across ministries and the private sector. The country has played an important role in advancing this agenda in the Asia-Pacific region and beyond. Given the importance of strengthening economic relations with emerging economies such as India and Brazil, as well as ASEAN member states, promoting responsible business conduct through Japan’s relevant trade policies creates further opportunities for Japanese companies and supply chains[4].
It should also be noted that before adopting the revised version of its National Action Plan on Business and Human Rights in December 2025, Japan had already had a National Action Plan on Business and Human Rights in place from October 2020, covering the implementation period from 2020 to 2025. That Plan constituted Japan’s first national framework for coordinating government policies, corporate responsibility, and the United Nations Guiding Principles on Business and Human Rights. The new version is, in fact, a revision and update of that earlier framework and seeks to bring Japan’s policy more closely into line with evolving international expectations regarding responsible business conduct by placing greater emphasis on human rights due diligence, supply chains, and support for small and medium-sized enterprises. The revised version was formulated in December 2025 and approved by the Inter-Ministerial Committee on 24 December of that year. Implementation was scheduled to begin at the start of Japan’s new fiscal year, on 1 April 2026. Through the implementation and promotion of the revised National Action Plan, the Government of Japan will continue to ensure policy coherence among relevant ministries and agencies in relation to business and human rights. The Government will promote responsible business conduct and, through this, contribute to the promotion and protection of human rights across society as a whole, including the international community[5].
The Plan also addresses emerging areas such as artificial intelligence. In light of the rapid expansion of generative AI, the revised version identifies AI and human rights as one of its key areas and emphasizes Japan’s participation in shaping international rules on generative AI in order to prevent adverse human rights impacts, including violations of privacy and the spread of misinformation[6]. Ultimately, by prioritizing eight key areas, the Plan seeks both to ensure victims’ access to remedies and to contribute to the achievement of the United Nations Sustainable Development Goals (SDGs). The Government also expects companies, by enhancing disclosure and transparency, to strengthen their credibility and brand value in global markets. The ultimate objective is to create a cycle of economic growth in which the rights of all individuals, particularly vulnerable groups, are fully respected[7].
To ensure that “no one is left behind,” the Plan also emphasizes the Government’s continued commitment to advancing gender equality and protecting the rights of foreign workers, persons with disabilities, children, and older persons. In addition, it sets out Japan’s intention to focus on contributing to the development of international rules on generative AI[8].
Challenges and Responses
- Shortcomings in the Implementation of Human Rights Due Diligence in Japan’s Private Sector
Kazuko Ito, a lecturer at Keio University Law School in Tokyo and a practicing lawyer in Japan, emphasizes in her analysis of the challenges facing Japan’s regulatory approach to business and human rights that, despite the adoption of the United Nations Guiding Principles in 2011, these principles had only a limited impact on the conduct of Japanese companies for a considerable period of time. Awareness and sensitivity within Japan’s private sector regarding human rights, both domestically and in countries where Japanese companies operate, also remained low. Although the Japanese Government has taken steps toward implementing the UN Guiding Principles—first by formulating a National Action Plan in 2020, then by issuing the Ministry of Economy, Trade and Industry’s Guidelines on Respecting Human Rights in Responsible Supply Chains in 2022, and in 2023 by incorporating human rights considerations into public procurement contracts—these measures have largely remained voluntary and non-binding.
Two surveys conducted in 2021 showed that most Japanese companies lacked adequate and appropriate policies to prevent human rights abuses in their supply chains. According to a Nikkei Asia survey conducted in June 2021, only 12 percent of Japanese companies were actively assessing human rights risks in their operations, even though nearly 80 percent regarded human rights violations as a growing business risk[9]. Ito further argues that the prevailing approach of both the Japanese Government and the business sector continues to rely on soft law, self-regulation, and support for small and medium-sized enterprises, while avoiding a shift toward mandatory human rights due diligence. She considers this approach insufficient and stresses that many companies have reduced human rights due diligence to superficial measures, such as adopting a human rights policy, sending questionnaires to suppliers, or outsourcing the entire process to consultants—practices that may become a means of concealing or cosmetically addressing potential human rights abuses. She also points to serious concerns raised by the United Nations Working Group regarding discrimination against minorities, gender discrimination and harassment, the inhumane conditions faced by workers connected with the Fukushima disaster, technical intern trainees, and a culture of impunity in the media and entertainment industry. In Ito’s view, effectively addressing these challenges requires Japan to establish a binding framework, an independent oversight body, civil liability for breaches of due diligence obligations, and clear government guidance in crisis situations such as Myanmar and the Uyghur issue[10].
- Domestic Responses
Reiko Fuchigami, President of the Japan Federation of Bar Associations, issued a statement setting out her position on Japan’s revised plan to promote respect for human rights in business. While welcoming the publication of the document on 24 December 2025, she described it as an important step toward aligning government policies with the United Nations Guiding Principles on Business and Human Rights. She emphasized that the Plan had been revised five years after the first version was adopted in 2020, taking into account developments within Japanese companies as well as international trends. The Japan Federation of Bar Associations particularly welcomed the Plan’s focus on eight priority areas, including access to remedy. At the same time, however, it noted that many of the shortcomings of the 2020 Plan remain unresolved. According to the Federation, the Government has yet to provide a sufficient analysis of gaps in the existing legal and policy framework, while the new Plan also fails to specifically address the reform of judicial barriers, the establishment of an independent national human rights institution, or an individual complaints mechanism. The Plan was also criticized for lacking a clear roadmap and specific indicators for measuring progress. Fuchigami stressed that achieving effective remedy for victims of human rights violations requires serious government initiative, sustained and meaningful dialogue with stakeholders, and the active involvement of specialized institutions. The Japan Federation of Bar Associations also announced that it would participate in dialogue, monitoring, and information-sharing mechanisms and would continue its efforts toward building a society grounded in respect for human rights[11].
The Japan External Trade Organization (JETRO) also announced on 23 January 2026 the establishment of its “Human Rights Policy Working Committee.” In a statement, it noted that because JETRO’s activities are closely connected with trade, investment, and global supply chains, they are directly linked to the issue of respect for human rights. JETRO emphasized that, in light of the adoption of the United Nations Guiding Principles on Business and Human Rights, Japan’s 2020–2025 National Action Plan, the Guidelines on Respecting Human Rights in Responsible Supply Chains, and the G7’s emphasis on respecting human rights in corporate activities, domestic and international expectations of economic institutions have increased. On this basis, JETRO stated that, in addition to conducting research, analysis, and awareness-raising on business and human rights, it must itself ensure respect for human rights in its organizational activities and promote responsible conduct among its business partners and the companies it supports. The purpose of the newly established Committee is to engage in dialogue with domestic and international stakeholders, clarify JETRO’s fundamental position on human rights, and establish a coherent foundation for the organization’s future initiatives in the field of responsible business conduct[12].
The Japan Business Federation (Keidanren), meanwhile, set out its views and concerns regarding the draft revised National Action Plan on Business and Human Rights in an official report published on its website. While emphasizing the need for management grounded in respect for human rights, it called on the Government to play a more active role in supporting companies. In particular, the Federation called for regular updates to government guidelines on respecting human rights in supply chains, the development of practical guidance on implementing human rights due diligence, and a clear distinction between minimum requirements and examples of good practice. It also emphasized the need to reduce the administrative burden on both buyers and suppliers and proposed that the Government develop standardized questionnaire templates, information-sharing platforms, and mechanisms to protect suppliers’ trade secrets. The Federation further urged the Government to provide clear and practical guidance on “enhanced due diligence” for Japanese companies operating in high-risk or conflict-affected areas and to conduct human rights impact assessments in projects related to development assistance. The establishment of free consultation centers inside and outside Japan, drawing on capacities such as those of JETRO, was another of its key requests[13].
- International Responses
The World Benchmarking Alliance (WBA) and the Business and Human Rights Centre (BHRC), in a joint statement, set out their position on Japan’s revised plan to promote respect for human rights in business. While welcoming the publication of the document, they emphasized the importance of transparent implementation and meaningful engagement with civil society and affected stakeholders. The two organizations identified as positive features of the new Plan its clearer focus on human rights due diligence, capacity-building for small and medium-sized enterprises, and its call on companies to identify, assess, prevent, mitigate, and remedy adverse human rights impacts. They also noted that some of the recommendations they had submitted during the public consultation process were reflected in the final text of the Plan, particularly with regard to ensuring that due diligence goes beyond mere risk identification, strengthening corporate transparency, and addressing supply chains. Nevertheless, they stressed that the revised Plan still fails to seize the important opportunity to move toward mandatory human rights due diligence and does not provide a clear pathway for addressing implementation gaps, particularly in global supply chains. In conclusion, the two organizations called on the Government of Japan, in implementing the Plan from April 2026 onward, to prioritize transparent monitoring, multi-stakeholder dialogue, effective evaluation indicators, and a readiness to strengthen the framework if voluntary approaches prove insufficient[14].
The International Labour Organization, in a report entitled “Turning Principles into Practice: Advancing Responsible Business Conduct in Japan,” published on 15 April 2026, also examined Japan’s efforts to link business and human rights policies with decent work standards and the fundamental rights of workers. The report emphasizes that, through the formulation of its National Action Plan on Business and Human Rights in 2020, its update in 2025, and the publication of voluntary guidelines on responsible supply chains, Japan entered this field more rapidly than many other Asian countries. At the same time, however, the ILO notes that policy frameworks can only be effective when governments, companies, and trade unions are able to implement them in practice. In this context, the “Resilient, Inclusive and Sustainable Supply Chains in Asia” (RISSC) project, supported financially by Japan since 2022, has worked to identify labour rights risks and strengthen stakeholder capacity in automotive supply chains in Thailand, aquaculture in the Philippines, and electronics in Indonesia. Since 2024, the project has also targeted companies, trade unions, and government institutions within Japan in order to translate responsible business conduct from principles and commitments into practical action. Within this framework, companies have received training on establishing worker grievance mechanisms, trade unions on using human rights due diligence to defend workers’ rights, and government officials on linking their day-to-day work with international labour standards. The ILO report ultimately stresses that developments in Japan do not remain confined within its national borders, as the standards and expectations of Japanese companies can be transmitted to their suppliers and production sites throughout Asia[15].
Conclusion
The revision of Japan’s National Action Plan on Business and Human Rights forms part of broader changes in economic governance, in which the boundary between business decision-making and human rights responsibility is gradually becoming less distinct. The position of Japanese companies within Asian and global supply chains means that the standards Tokyo establishes for human rights due diligence, transparency, the treatment of suppliers, the protection of workers, and emerging technologies may potentially have effects extending beyond the country’s borders. From this perspective, the significance of Japan’s new Plan lies not only in the range of issues it covers, but also in its capacity to transform human rights from a secondary consideration in corporate management into part of the logic of economic decision-making and business risk assessment.
Nevertheless, the decisive issue remains the gap between what is expected of companies and what they are legally required to do. The significant reliance of Japan’s framework on guidelines, self-regulation, and voluntary mechanisms leaves open the question of what will compel companies to change their conduct when respect for human rights conflicts with short-term economic interests. The absence of a comprehensive mandatory framework for human rights due diligence, weaknesses in certain monitoring and remedial mechanisms, and the lack of clear indicators for measuring performance may allow the gap between stated policy and practical outcomes to persist. Accordingly, the success of the revised Plan should be assessed not by the number of commitments and guidelines it contains, but by its ability to identify risks at an early stage, prevent violations, bring about changes in corporate conduct, and provide rights-holders with access to effective remedy. In this sense, Japan now stands at a critical juncture: it will either turn human rights due diligence into a genuine component of corporate governance or remain at the boundary between voluntary responsibility and legally enforceable accountability.
References
[1] The Office of the High Commissioner for Human Rights. (n.d). National action plans on business and human rightsy, Working Group on Business and Human Rights. OHCHR. From: https://www.ohchr.org/en/special-procedures/wg-business/national-action-plans-business-and-human-rights
[2] Government of Netherlands. (n.d). Revised National Action Plan on Business and Human Rights. Government of Netherlands. From: https://www.government.nl/themes/economy/responsible-business-conduct-rbc/national-action-plan-on-business-and-human-rights
[3] United Nations Responsible Business and Human Rights Forum, Asia-Pacific. (2025, September 16). From Commitment to Practice: Reviewing National Action Plans on Business and Human Rights in Southeast Asia. United Nations Responsible Business and Human Rights Forum, Asia-Pacific. From: https://www.rbhrforum.com/commitment-to-practice
[4] UNDP. (2026, January 9). Annual Business and Human Rights Dialogue in Tokyo. UNDP. From: https://www.undp.org/rolhr/events/annual-bhr-dialogue-tokyo
[5] Ministry of Foreign Affairs of Japan. (2025, December 24). Revision of Japan’s National Action Plan on Business and Human Rights. Ministry of Foreign Affairs of Japan. From: https://www.mofa.go.jp/press/release/pressite_000001_01964.html
[6] Jiji. (2025, October 7). Japan’s revised corporate action plan on human rights to prioritize small firms. Japan Times. From: https://www.japantimes.co.jp/news/2025/10/07/japan/society/japan-corporate-human-rights-action-plan/
[7] Ministry of Foreign Affairs of Japan. (2025, December). National Action Plan on Business and Human Rights. Ministry of Foreign Affairs of Japan. From: https://www.mofa.go.jp/files/101013260.pdf
[8] Jiji. (2025, October 6). Japan: Draft revision of National Action Plan on Business and Human Rights identifies implementation of human rights due diligence and support for SMEs as priority areas. Business and Human Rights Centre (BHRC). From: https://www.business-humanrights.org/en/latest-news/japan-draft-revision-of-national-action-plan-on-business-and-human-rights-identifies-implementation-of-human-rights-due-diligence-and-support-for-smes-as-priority-areas/
[9] Flacks, M., & Songy, M. (2022, May 19). Japan’s Human Rights Guidelines for Companies Provide an Opportunity for Global Leadership. Center for Strategic & International Studies. From: https://www.csis.org/analysis/japans-human-rights-guidelines-companies-provide-opportunity-global-leadership
[10] Ito, K. (2024, June 25). Challenges for Japan’s Regulatory Approaches for Business and Human Rights. BHRJ Blog. From: https://bhrj.blog/2024/06/25/challenges-for-japans-regulatory-approaches-for-business-and-human-rights/
[11] Fuchigami, R. (2026, February 19). Statement on Revised Edition of the National Action Plan on Business and Human Rights Published by the Japanese Government. Japan Federation of Bar Associations. From: https://www.nichibenren.or.jp/en/document/statements/260219.html
[12] Japan External Trade Organization. (2026, January 23). Notification on the Establishment of JETRO’s Human Rights Policy Working Committee. Jetro. From: https://www.jetro.go.jp/en/news/announcement/2026/391ca90b5dec9de9.html
[13] Keidanren. (2025, October 28). Opinion on the Draft Revised National Action Plan on Business and Human Rights. Keidanren. From: https://www.keidanren.or.jp/policy/2025/074.html
[14] World Benchmarking Alliance. (2026, March 3). World Benchmarking Alliance and Business Human Rights Centre’s statement on Japan’s revised National Action Plan on Business and Human Rights. WBA. From: https://www.worldbenchmarkingalliance.org/world-benchmarking-alliance-and-business-human-rights-centres-statement-japans-revised-national
[15] International Labour Organization. (2026, April 15). Turning principles into practice: advancing responsible business conduct in Japan. ILO. From: https://www.ilo.org/resource/news/turning-principles-practice-advancing-responsible-business-conduct-japan
