On the Horizon — Not Yet Law
Amendments to the Act on the Protection of Personal Information introducing protections for individuals under 16
Once in force, the amendments would require parental or guardian consent and guardian-facing notice for processing the personal data of individuals under 16, subject to limited exceptions, and would give children enhanced rights to request deletion or suspension of use. Reporting also indicates a 'best interests' test for data describing minors and an explicit parental-approval requirement for collecting biometrics from an under-16, alongside the amendment package's broader new rules on biometric data. For a business serving Japanese users this would be a material change from the current position, where children's protection rests on interpretive guidance rather than on a statutory age line.
Status: Not yet operative. Japan currently has no statutory children's consent age — the PPC's Q&A guidance treats children aged roughly 12 to 15 or younger as generally lacking decision-making capacity, assessed case by case, which is guidance rather than a rule. The 2026 amendment package changes that by putting an under-16 threshold into the Act itself. Independent sources describe its status inconsistently, some as a bill and some as enacted in July 2026, so confirm the current position before relying on it. Full enforcement is expected around April 2028, and much of the operative detail depends on Cabinet Orders and PPC regulations and guidelines that had not been issued.
Approximately April 2028 (expected full enforcement)
This is a general reference, not legal advice or a determination that this law applies to your specific business. Run the full questionnaire to check against your actual presence, activities, and data types.