Japan vs South Korea

Dimension

Japan

South Korea

Status

Act in force (soft-law)

In Effect (Jan 22, 2026)

Max penalty

No AI-specific penalty (promotion statute); APPI up to ¥100M for corporations on a PPC-order breach

Administrative fines up to KRW 30 million

Key deadline

Act in force (June–Sept 2025)

Effective January 22, 2026 (fines after a one-year grace period)

# of instruments

4

3

Headline rule

AI Promotion Act — Act on the Promotion of R&D and Utilization of AI-Related Technologies (2025)

Basic Act on the Development of AI and Establishment of Trust (AI Basic Act, effective Jan 22, 2026)

What it requires

Japan has confirmed an innovation-first, light-touch approach. The AI Promotion Act, passed in May 2025, is a promotion statute: it sets national principles and creates a Prime-Minister-chaired AI Strategy Headquarters, but imposes no prohibitions or monetary penalties on businesses. Companies are expected to voluntarily follow the METI/MIC AI Guidelines for Business (human-centricity, safety, fairness, transparency, accountability); the only real legal exposure for AI-related data handling comes via the existing APPI privacy regime, enforced by the Personal Information Protection Commission.

South Korea's AI Basic Act — the first comprehensive national AI framework in Asia — took effect on January 22, 2026, with a one-year grace period before fines are enforced. Operators must determine whether their system is 'high-impact AI' (used in healthcare, hiring, biometrics, or public services) and, if so, provide explanations of outputs, ensure human oversight, and run risk and fundamental-rights impact assessments. All providers must label AI-generated content and disclose AI interaction; large foreign providers must appoint a Korea-based domestic representative. Administrative fines reach KRW 30 million.