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Foreword

The results of NAVEX’s 2026 State of Risk & Compliance Report survey indicate that Japanese companies’ compliance and ethics programs are broadly aligned with international standards. Senior executives in Japan demonstrate a level of ethical awareness comparable to that of their global counterparts and generally hold positive views of the use of artificial intelligence in compliance-related activities. This suggests that Japanese organizations recognize AI’s potential to improve risk management, monitoring, and compliance processes.  

However, the survey also highlights several notable challenges  Japanese businesses face. By understanding their specific needs and priorities, companies can make more informed decisions about where to allocate resources and investments. This report aims to support organizations in this process by providing insights that can help them develop, strengthen, and implement more effective ethics and compliance initiatives in an increasingly complex business environment

Japanese companies are generally aligned with global compliance maturity

According to this survey, Japanese companies’ risk management and compliance (R&C) programs, as well as their level of maturity, are generally on par with the global average.  
  
When referencing program maturity, NAVEX aligns with the  Ethics and Compliance Initiative (ECI) High-Quality Program (HQP). Japanese companies’ risk management and compliance (R&C) programs are generally aligned with the global average, and program maturity levels are also broadly aligned. 

Japanese organizations report a strong level of program maturity, closely mirroring global benchmarks, with the majority at the Managing or Optimizing stage. Notably, fewer Japanese companies describe their programs as underdeveloped compared to the global average, suggesting a solid foundation across the region.

Leadership sets a good example, but data shows some strain under pressure

In Japan, most respondents painted a positive picture of leadership. Sixty-three percent of respondents said senior executives set a good example of appropriate behavior, exceeding the global average of 55%. In addition, eighty-eight percent of respondents from Japanese companies did not state they have witnessed senior managers encouraging employees to engage in unethical behavior to achieve business objectives.  

But does the commitment to compliance hold up under pressure? Asked if senior executives have maintained a commitment to ethics when faced with conflicting interests, 32% of respondents in Japan said “yes.” That’s much lower than the 50% global response rate.

Speak-up programs are high priority, but fear of retaliation remains

A “speak-up” culture represents a broader organizational approach that empowers employees to take a more active role in identifying and addressing issues by raising concerns through the internal reporting channels available. This approach creates value for both the organization and its workforce while strengthening overall organizational resilience. In addition, fostering an environment that promotes open communication can contribute to reducing employee turnover. This is particularly significant in Japan, where labor shortages are intensifying due to demographic challenges, including a declining birthrate and an aging population.  

In Japanese companies, many systems for speaking up are still in their early stages of development. These companies have room to further strengthen their commitment.

J-SOX: Still influential even now, nearly 20 years after it took effect

J-SOX continues to drive change even 20 years after its enactment. Like its U.S. model, the 2002 Sarbanes-Oxley Act, it continues to shape corporate behavior broadly and substantially regardless of the severity of a company’s compliance issues. However, the law is not compelling Japanese companies to address some critical issues, such as third-party risk. 

Organizational circumstances can change over time. Companies that initially faced challenges in complying with newly introduced legislation may have since developed the structures and processes required to achieve full compliance.

AI expansion expected in Japan

When respondents were asked about their adoption outlook for the next 12 months, an ambitious stance emerged. Japanese companies plan to significantly expand their use of AI and further advance its implementation in compliance operations. Its use in monitoring and surveillance is expected to nearly double. Similarly, significant growth is anticipated in investigative support, such as evidence review, pattern detection, and report generation. 

Although the baseline is low, the use of AI for third-party risk screening and due diligence is expected to nearly double in the next 12 months. However, only one-quarter of Japanese companies expect to leverage AI to address this critical gap in their own programs, even 12 months from now.

These survey results indicate that Japanese companies’ compliance programs are generally aligned with global standards, including in terms of program maturity. At the same time, the findings highlight several areas that require further improvement. 

These challenges extend beyond the establishment of policies, systems, and processes; they are closely linked to organizational culture. To further enhance compliance programs, companies must not only secure strong leadership and commitment from senior management and the board of directors but also cultivate an environment in which employees feel empowered to raise concerns. 

Japanese companies have established a strong foundation for compliance, supported by mature programs and a high level of ethical awareness among senior leaders. However, maintaining this foundation requires continuous evolution. Download the full State of Risk & Compliance in Japan report to explore detailed findings, benchmarks and recommendations for strengthening your compliance program.

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