Japan Copyright Act Article 30-4 and AI Training

Article 30-4 of Japan’s Copyright Act is a limitation on copyright, not an unrestricted AI-training license. The English translation states that a person may exploit a work, to the extent considered necessary, in cases including technology testing, data analysis and certain computer processing, when the person’s purpose is not to personally enjoy or cause others to enjoy the thoughts or sentiments expressed in the work. The proviso withdraws the exception where the use would unreasonably prejudice the copyright owner’s interests in light of the work, purpose or circumstances. The Japanese Agency for Cultural Affairs (ACA) explains that collecting copyrighted works as AI training data may, in principle, fall within Article 30-4 where the use is for non-enjoyment analysis. The rule is not limited to noncommercial uses, but commerciality alone does not determine whether it applies. Conversely, labeling a process “training” is not decisive. The ACA’s 2024 General Understanding says Article 30-4 does not cover reproduction where a purpose of enjoying the work’s expression coexists, such as intentional additional training to generate outputs similar to collected works or RAG that aims to output a source work’s creative expression. It also discusses the proviso where analysis databases are licensed in the market or technical measures designed to prevent collection are avoided. These are agency interpretations of current law, not amendments, binding court rulings or definitive outcomes for every model and dataset. Questions about a particular work, purpose, necessity, database market, acquisition method and output require fact-specific analysis. Training-stage permission also does not automatically authorize later output or publication. Similarity and dependence, Article 47-5 or another exception may matter separately. The law’s English text is an official translation resource, but the Japanese enacted text controls.