World Benchmarking Alliance and Business Human Rights' statement on Japan's revised National Action Plan on Business and Human Rights 

Statement on Japan’s revised National Action Plan on Business and Human Rights

The Japanese government published the revised Japan’s National Action Plan on Business and Human Rights (NAP) on 24 December 2025. The World Benchmarking Alliance (WBA) and the Business and Human Rights Centre (BHRC) welcome the publication of the revised NAP, and underscore the importance of transparent and meaningful engagement with civil society and affected stakeholders throughout its implementation.

The revised NAP defines the Government’s approach to business and human rights across eight priority areas. We welcome the clearer emphasis on human rights due diligence and capacity-building for small and medium-sized enterprises, as well as the call for companies to implement human rights due diligence, including the identification, assessment, prevention, mitigation, and remediation of adverse impacts.  

We are encouraged to see that several of the public comment submitted by WBA and BHRC during the consultation process, which resonated strongly with the perspectives of our allies and partners, have been incorporated into the final text, as evidenced by the Government’s publication of a response-to-comments document. In particular, the revised NAP:

• Clarifies expectations for effective human rights due diligence, emphasising that it must go beyond risk identification to include prevention, mitigation, tracking and remedy, in line with the UN Guiding Principles on Business and Human Rights.
• Strengthens references to meaningful stakeholder engagement and practical action in supply chains, including addressing the gap between identifying human rights risks and taking effective action.
• Reinforces the importance of transparency and corporate disclosure, including through continued reference to third-party benchmarks such as the Corporate Human Rights Benchmark (CHRB).

At the same time, meaningful implementation will require that these considerations be translated into concrete policy development and implementation measures as the NAP is carried out.

Nevertheless, the revised version still misses several important opportunities. It stops short of signalling a move toward mandatory human rights due diligence, despite growing international momentum in this direction. While the NAP references the EU Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD), it does not yet set out a clear pathway for ensuring a level playing field or for addressing persistent implementation gaps, particularly in global supply chains.

Further attention will be needed to:

• Strengthen expectations for meaningful stakeholder engagement and the implementation of comprehensive human rights due diligence across entire supply chains;
• Articulate clearer commitments to ensuring a just transition, given that adverse impacts related to environmental and human rights issues disproportionately affect local communities, Indigenous Peoples, and human rights defenders;
• Introduce adequate indicators and monitoring mechanisms to measure the effectiveness of the actions set out in the NAP and track progress over time.

As implementation of the revised NAP is set to begin in April 2026, WBA and BHRC encourage the Japanese government to prioritise transparent monitoring, meaningful multi-stakeholder engagement and continued openness to strengthening the framework where voluntary approaches prove insufficient. In light of concerns raised regarding stakeholder engagement during the NAP revision process, we emphasise the importance of ensuring that the implementation, monitoring and evaluation of the NAP are fully transparent and incorporate meaningful engagement with stakeholders, including civil society organisations and rightsholders.

With clear direction, accountability and sustained engagement, Japan has an opportunity to build on recent progress and further advance responsible business conduct in line with evolving international expectations. BHRC and WBA stand ready to support effective implementation through evidence-based insights, benchmarking data, and constructive dialogue with stakeholders.