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The EU AI Act for Japanese companies: scope, AI literacy and key dates

General information, not legal advice. Quotes are taken from the official EU texts listed under Sources; check them and take advice for your own case. Using Unadhi tools does not make an organisation compliant.

1. When the Act reaches a Japanese company (Article 2(1))

Being based in Japan does not by itself take a company outside the EU AI Act. Article 2(1) of Regulation (EU) 2024/1689 says the Regulation applies to, among others:

(a) providers placing on the market or putting into service AI systems or placing on the market general-purpose AI models in the Union, irrespective of whether those providers are established or located within the Union or in a third country;
(c) providers and deployers of AI systems that have their place of establishment or are located in a third country, where the output produced by the AI system is used in the Union;

The list also covers (b) deployers in the Union, (d) importers and distributors of AI systems, (e) product manufacturers placing an AI system on the market together with their product under their own name or trademark, (f) authorised representatives of providers not established in the Union, and (g) affected persons located in the Union.

In practice, ask for each AI system: do we sell or supply it into the EU (point (a))? Is its output used in the EU, for example by EU customers, staff or a subsidiary (point (c))? Is it built into a product we sell in the EU under our name (point (e))?

2. AI literacy (Article 4, as replaced by Regulation (EU) 2026/1744)

Regulation (EU) 2026/1744 of 8 July 2026 (the "Digital Omnibus on AI") replaced Article 4. Paragraph 1 now reads:

Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used. This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.

Paragraph 2 says the Commission and the Member States shall support providers and deployers, in particular SMEs, and that the Commission shall publish practical examples of how to comply.

3. Key dates (Article 113, as amended)

Article 113 of the consolidated text says the Regulation "shall apply from 2 August 2026", with these exceptions:

Article 4 is in Chapter I.

4. Practical steps

  1. List every AI system you build, sell or use, including tools from vendors.
  2. For each one, note your role (provider, deployer, importer, distributor, product manufacturer) and whether it is placed on the EU market or its output is used in the EU.
  3. Screen each system for the categories that matter for the dates above (for example, Annex III uses), and record who reviewed it and when.
  4. Record your AI literacy measures for staff and others who operate or use AI on your behalf.
  5. Keep the evidence (vendor documents, training records, review notes) together, and set a next-review date.

Already working with Japan's own framework? See our AI Guidelines for Business Ver1.2 checklist and AI Promotion Act guide.

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Sources

← Unadhi Japan guides