Japan's Ministry of Justice published the final report of its review committee on civil liability for unauthorised use of likenesses and voices, subtitled interpretive guidelines on publicity rights infringement by generative AI, dated August 2026. The committee held five meetings, the last of them on 27 July 2026. The report is interpretive guidance on law already in force. It is not legislation and no bill accompanies it.
Chapter 1 sets out the general law protecting likenesses and voices in three sections: publicity rights at Section 1, the right not to have one's likeness or voice used improperly at Section 2, and the Unfair Competition Prevention Act at Section 3. The publicity rights analysis rests on judge-made personality rights rather than a numbered Civil Code provision. The controlling authority is the Supreme Court's Pink Lady judgment of 2 February 2012, reported at Minshu volume 66, number 2, page 89, which grounded publicity rights in personality rights and identified three categories of infringing use. Chapter 2 applies that law to seven scenarios, with a supplementary discussion on acts of providing generative AI services.
Voice actors and singers gain a stated basis for arguing that synthesised reproduction of their voice engages publicity rights, which the committee reaches by treating a voice as both identifying information and a mark of personality, and so within the Supreme Court's category of likeness and the like. Music distributors and platforms carrying AI voice covers are reached by the scenario on unauthorised use of a singer's or voice actor's voice in distributed audio. Operators of voice cloning and speech synthesis services are addressed through the supplementary discussion on service provision rather than through the primary analysis of the person generating the output.
The report is explicit that it works without case law: it was commissioned because the scope of infringement is unclear and no court has ruled on generative AI facts. It therefore reads existing doctrine rather than settling it, and the split of liability between a service operator and the user who generates an output is raised in the supplementary discussion without a firm conclusion. No deadline or compliance date attaches to the report.
Licentium advises voice talent, rights holders, music distributors and operators of voice synthesis services on personality and publicity rights exposure in Japan and in comparable regimes. Work we undertake includes assessment of voice and likeness claims against the Pink Lady criteria, review of consent and licence wording for synthetic voice use, allocation of liability between model operators and end users, and takedown and enforcement strategy.