Japan: Japan Fair Trade Commission released guide on development and operation of effective Antimonopoly Act compliance programs

On 20 June 2025, the Japan Fair Trade Commission (JFTC) released the results of a fact-finding survey on the development and operation of Antimonopoly Act compliance programs in companies, along with a revised version of the guide to the development and operation of effective Antimonopoly Act compliance programs. The survey, conducted for the first time since 2012, targeted Tokyo Stock Exchange Prime Market-listed companies and examined the status of establishing and operating compliance frameworks, including responses to risks related to algorithmic collusion, Artificial Intelligence (AI) utilisation in antitrust audits, labour cost pass-through, prevention and early detection of private monopolisation and unfair trade practices, and initiatives among small and medium-sized enterprises. Based on findings from questionnaire and interview surveys, the Commission also analysed historical cases of Antimonopoly Act violations, including enforcement outcomes, to identify systemic failures and inform the updated guide. The revised guide incorporates guidance on emerging issues, practical examples from the survey, and reference points for drafting internal regulations, aiming to further enhance the effectiveness of corporate compliance programs with the Antimonopoly Act.