Japan — Open Records Law

Response Timeline

Initial Response

30 days

Extension

30 days

Residency Required

None

30 calendar days from the date of the disclosure request (Article 10, Paragraph 1). Extendable by up to 30 additional days (60 total) when there are justifiable operational reasons (Article 10, Paragraph 2). The agency must notify the requester in writing, stating the reasons for the extension and the expected decision date. For exceptionally voluminous requests (Article 11), the agency may disclose a "reasonable portion" within 60 days and process the remainder within a reasonable period.

Article 3 grants the right to request disclosure to "any person" (何人も). This includes Japanese citizens, foreign nationals, non-residents, and corporations (both domestic and foreign). There is no requirement to state the purpose of the request.

How to Submit a Request

Accepted Methods

Requests must be submitted on a prescribed disclosure request form (開示請求書) (Article 4). Accepted in person at the agency's information disclosure counter (情報公開窓口) or by mail with the 300 yen revenue stamp attached. Most agencies do not accept requests by fax or email. There is no central portal -- each administrative organ handles its own requests separately.

Required Elements

{'note': "Name and address (or residence) of the requester; for corporations, the name and representative's name (Article 4)", 'field': 'name_address'}
{'note': 'Description of the administrative documents: the title or other information sufficient to identify the specific documents being requested (Article 4)', 'field': 'document_description'}

Optional Elements

{'note': 'Preferred method of disclosure (viewing, photocopy, electronic media, etc.)', 'field': 'preferred_format'}
{'note': 'Phone number or other contact details to facilitate communication', 'field': 'contact_details'}

Fees

The JPY 300 request fee is non-refundable regardless of outcome. Implementation fees are charged only when documents are actually disclosed, and the first JPY 300 worth is waived (offset against the request fee already paid). Fees are designed to be "as affordable as possible" (Article 16, Paragraph 1). Payment is by revenue stamps (収入印紙) affixed to the request form.

Fee Waivers

{'name': 'Economic Hardship', 'waives': ['request_fee', 'implementation_fee'], 'category': 'discretionary', 'criteria': ['Requester has difficulty paying due to financial circumstances'], 'how_to_apply': 'Request waiver from the agency head'}
{'name': 'Other Special Reasons', 'waives': ['request_fee', 'implementation_fee'], 'category': 'discretionary', 'criteria': ['Other special reasons as determined by the agency head'], 'how_to_apply': 'Request waiver from the agency head'}

Article 16, Paragraph 2 provides for fee reduction or exemption for economic hardship or "other special reasons." There is no explicit public interest fee waiver (unlike the US FOIA). Waiver of up to JPY 2,000 is available for economic hardship.

Exemptions

Personal Information

Information relating to an individual that can identify a specific person by name, date of birth, or other description, or could identify a person when collated with other information. Exceptions: information already lawfully public, information necessary to protect life/health/property, and information about public officials in their official capacity.
Corporate/Business Information

Information related to a corporation or individual's business where disclosure would harm rights, competitive position, or other legitimate interests; or information voluntarily provided on condition of non-disclosure.
National Security and Foreign Affairs

Information that the agency head has reasonable grounds to deem, if disclosed, would be likely to harm national security, damage foreign relations, or cause disadvantage in international negotiations.
Public Safety and Law Enforcement

Information that, if disclosed, would be likely to hinder crime prevention/investigation, impede public prosecutions, impede execution of sentences, or otherwise hinder maintenance of public safety and order.
Deliberative Process

Information concerning deliberations, examinations, or consultations within or between government organs, where disclosure would cause unjust harm to frank exchange of opinions, neutrality of decision-making, or cause unjust confusion among the people.
Administrative Operations

Information that, if disclosed, would hinder proper performance of administrative operations, including audits, inspections, contracts, negotiations, personnel management, state enterprise management, and research activities.

All six exemption categories are listed in Article 5 and are formally mandatory (the agency "shall not disclose"). However, Article 7 provides a discretionary public interest override: even when information falls within an exemption, the agency head may disclose it when "there is a particular public-interest necessity." Article 6 requires partial disclosure when only part of the information is exempt. Article 8 permits "Glomar" responses (refusing to confirm or deny existence) when merely acknowledging existence would itself disclose exempt information.

Appeal Process

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2

3

The appeal system has two parallel pathways: administrative review (via the Review Board) and judicial review (via district court). There is no requirement to exhaust administrative remedies before filing suit. The Review Board's advisory opinions are non-binding but are generally followed, with less than 10% of cases proceeding to court after the Board issues its opinion. Article 36's special venue provision was a significant reform allowing suits at 8 High Court seat district courts rather than only the agency's location, though advocates sought even broader venue at the plaintiff's local district court.

Request Templates

MIC Information Disclosure System Overview

MIC Fee Schedule

Cabinet Secretariat Disclosure Forms

Records Retention

Retention Law

Public Records and Archives Management Act

Authority

National Archives of Japan (国立公文書館)

Act No. 66 of July 1, 2009 (公文書等の管理に関する法律)

View retention law →

Retention schedule catalog →

Enacted 2009; requires government-wide unified rules for creating and managing public records. Administrative documents must be retained for specified periods; historically valuable records are transferred to the National Archives for permanent preservation.

Act on Access to Information Held by Administrative Organs