Hello, this is Ryuta Hamamoto from TIMEWELL. "So does the Economic Security Promotion Act actually apply to us?" For about two years now, this has been the single most common question I get, regardless of industry. Not semiconductor makers or defense contractors, but ordinary manufacturers, infrastructure operators, and even university researchers—everyone carries a similar unease. They know the name. They saw it in the news. But the moment they open the statute, the wall of technical jargon stops them.
To be honest, this law will defeat you every time if you try to understand it all at once. That is because four completely different regimes are bundled into a single statute. Put the other way around: once you grasp the outline of those four pillars, you can get a sense of which of them your company actually needs to face. I wrote this article to let you take in the whole picture of the Economic Security Promotion Act on one page, and to serve as an entry point from which you can move on to the detailed practice of each regime. I unpack technical terms the first time they appear. For now, relax your shoulders and read on as if you were looking over a map.
If you would first like to know how far your company is already prepared on export control and counterparty screening, our free export control assessment lets you grasp your current gaps in about three minutes. Economic security and export control are, as I will explain later, contiguous.
What Is the Economic Security Promotion Act in the First Place?
The formal name of the Economic Security Promotion Act is the "Act on the Promotion of Ensuring Security by Taking Economic Measures in an Integrated Manner." It is a long name, but the aim of the regime is distilled right into it. Traditionally, security was a matter of defense and diplomacy. Yet problems such as semiconductor shortages, rare-earth supply restrictions, infrastructure outages caused by cyberattacks, and the leakage of sensitive technology cannot be defended with a defense budget. They happen at the very heart of the economy. So the idea was to secure national safety by "taking economic measures in an integrated manner," and the comprehensive law built on that idea is this statute.
The statute number is Act No. 43 of 2022. It was enacted on May 11, 2022 and promulgated on May 18 of the same month. The command center for the entire regime is the Cabinet Office, where the Director-General for Policy Planning (Economic Security) handles overall coordination. As a related mechanism, a Security Clearance system, under which the state verifies individuals who handle sensitive information (the "Act on the Protection and Use of Critical Economic Security Information," Act No. 27 of 2024), has also been established under the jurisdiction of the Cabinet Office and is operated in tandem with the Economic Security Promotion Act. If you would like to trace the fundamentals of how it came about a bit more carefully, take a look at The Basics of Economic Security Law as well.
What I would like you to hold onto here is that this law is not the type of regulation that "uniformly prohibits" something. One pillar backs companies with subsidies, another imposes pre-screening on the introduction of equipment, and yet another keeps patents non-public. Regimes of entirely different character coexist. That is precisely why the first step is the work of discerning which pillar applies to your company.
Taking In the Four Pillars and the Phased Enforcement on One Page
The Economic Security Promotion Act is composed of the following four pillars. The first is ensuring the stable supply of critical goods—what is commonly called supply-chain resilience. The second is ensuring the stable provision of core infrastructure services such as electricity, telecommunications, and finance. The third is support for the development of advanced critical technologies. And the fourth is the non-disclosure of patent applications. Think of these four as different things in their aims, in the ministries with jurisdiction, and in the response they demand of companies.
Another important point is that they did not all start at once. The regime was enforced in phases. In September 2022, the basic policy common to the four pillars, along with the basic guidelines for the first pillar (critical goods) and the third pillar (advanced technology), were approved by the Cabinet, and operation began. Next, in April 2023, the basic guidelines for the second pillar (core infrastructure) and the fourth pillar (patent non-disclosure) were approved by the Cabinet, and both regimes began operation in May 2024. This time lag reflects the difference in weight from regime to regime.
| Timing | Development | Pillar(s) concerned |
|---|---|---|
| September 2022 | Overall basic policy and basic guidelines for pillars 1 and 3 approved by Cabinet; operation begins | Pillar 1 (critical goods) and Pillar 3 (advanced technology) |
| April 2023 | Basic guidelines for pillars 2 and 4 approved by Cabinet | Pillar 2 (core infrastructure) and Pillar 4 (patent non-disclosure) |
| May 1, 2024 | Operation of the patent non-disclosure system begins | Pillar 4 (patent non-disclosure) |
| May 17, 2024 | Operation of pre-screening for core infrastructure begins | Pillar 2 (core infrastructure) |
Keep this table in the back of your mind and the explanations of each pillar that follow will connect along a single line. From here, I will look at the four pillars one by one, from the perspective of corporate practice.
Replace siloed classification work with AI.
METI's FY2024 data shows 52% of foreign exchange law violations stem from classification errors. Download the TRAFEED product catalog covering features and rollout.
Pillar 1: Strengthening the Supply Chains of Critical Goods
The first pillar is a regime in which the state backs the building of systems that can stably supply goods indispensable to citizens' lives and to economic activity. The state designates particularly important items as "specified critical materials." By a Cabinet Order in December 2022, 11 materials were designated first: antimicrobial agents, fertilizers, permanent magnets, machine tools and industrial robots, aircraft parts, semiconductors, storage batteries, cloud programs, natural gas, critical minerals, and ship parts. Simply glancing over the names, you begin to see where the foundations of daily life and industry lie.
The designations have continued to expand since then. In February 2024, advanced electronic components (capacitors and filters) were added, and uranium was added to critical minerals. Further, in December 2025, ventilators, unmanned aircraft, artificial satellites, and rocket parts were newly designated; ship hulls were added to ship parts, and magnetic sensors were added to advanced electronic components. It is best to understand that the scope is updated each time a risk of emergency or supply disruption materializes.
What draws the strongest corporate interest is the support measures. The minister with jurisdiction over a given material establishes and publishes a "policy on efforts to ensure stable supply." Based on it, a business operator prepares a supply-securing plan, and once certified, can receive support such as subsidies, two-step loans (long-term, low-interest, fixed-rate financing), share subscriptions, and credit guarantees. The scale is concrete, too. According to the Cabinet Office, as of July 14, 2026, the total of the maximum subsidy amounts was approximately 1.68 trillion yen, and the number of certified supply-securing plans reached 151 (please note that these figures are updated from time to time). Jurisdiction over each material is divided among the Ministry of Health, Labour and Welfare, the Ministry of Agriculture, Forestry and Fisheries, the Ministry of Economy, Trade and Industry, the Ministry of Land, Infrastructure, Transport and Tourism, and the Agency for Natural Resources and Energy. Which material do your products fall under, and whose policy on efforts should you be reading? The specific way to look this up and the practicalities of applying are explored in depth in Detailed Guide to Specified Critical Materials and Supply-Securing Plans.
Pillar 2: Stable Provision of Core Infrastructure Services
The second pillar is a regime that keeps the infrastructure forming society's foundation from being stopped by external interference. The scope is called "specified critical infrastructure services," and 15 sectors were designated at the outset: electricity, gas, oil, water supply, railways, freight motor transport, ocean-going cargo, aviation, airports, port transport, telecommunications, broadcasting, postal services, finance, and credit cards. Later, the healthcare sector was added on June 17, 2026, so that the lifelines supporting daily life are now broadly covered.
The linchpin of this regime is pre-screening. When a covered operator newly introduces critical equipment—so-called specified critical equipment—or outsources its important maintenance and management to an external party, it must notify the state in advance and undergo screening. Notification is done by email or through the e-Gov electronic application service. What is screened is whether an act that could interfere with the functioning of the infrastructure might be embedded through that equipment or that contractor. Because the field of view extends not only to the supplier but to sub-contractors further downstream, the management of procurement and outsourcing is being tested more than ever. Jurisdiction is held by the Ministry of Economy, Trade and Industry for electricity, gas, oil, and credit cards; the Ministry of Land, Infrastructure, Transport and Tourism for water supply, railways, transport, ocean-going cargo, aviation, airports, and port transport; the Ministry of Internal Affairs and Communications for telecommunications, broadcasting, and postal services; and the Financial Services Agency and the Ministry of Agriculture, Forestry and Fisheries for finance.
If your company is an infrastructure operator, the thorniest issue is the attribute screening of contractors. How far back should you trace, and what should you confirm? The flow of this screening and the practicalities of contractor screening are laid out concretely in Detailed Guide to the Core Infrastructure Pre-Screening System. For the points that operators handling data centers, the cloud, or IoT devices should master, see Data Centers, Cloud, IoT and Economic Security; for the response prompted by the addition of the healthcare sector, see Guide to Economic Security in the Healthcare Sector.
Pillar 3: Support for the Development of Advanced Critical Technologies
The third pillar has a different character from the previous three, because it is neither regulation nor screening—it is support. It is a mechanism in which the state, uniting the public and private sectors, nurtures advanced technologies—AI, quantum, space, ocean, bio—that will determine future security and industrial competitiveness. At its core is the "Key and Advanced Technology R&D through Cross Community Collaboration Program," commonly called the K Program. Its inaugural meeting was held on June 21, 2022.
A defining feature of this regime is its "running-alongside" design, which does not simply cast researchers out on their own. The state establishes a forum called the "Council for a Designated Fund for R&D of Specified Critical Technologies," where the public and private sectors advance the direction of research, its social implementation, and the handling of sensitive information through dialogue. Councils have been set up one after another, and at least up to No. 42 can be confirmed. The implementing bodies that handle the actual public solicitations and R&D are the Japan Science and Technology Agency (JST) and the New Energy and Industrial Technology Development Organization (NEDO). Each institution is advancing on the order of a dozen-plus R&D concepts, with themes spanning the ocean field such as underwater wireless communication and next-generation vessels; the space and aviation field such as high-altitude unmanned aircraft and satellite refueling; cross-domain and cyberspace fields such as cyber defense, cryptography, semiconductors, storage batteries, and materials; and the bio field such as hemostatic agents, brain-tech, and fertilizers. Jurisdiction rests with the Cabinet Office, plus the Ministry of Economy, Trade and Industry and the Ministry of Education, Culture, Sports, Science and Technology.
As for the fund size of the K Program, published materials refer to it in different ways, and in the primary-source verification for this article I could not pin down a definitive total. Rather than assert a figure, I recommend first discerning whether your company's research theme overlaps with the solicitation areas. How to use the regime, how to find solicitations, and the technology-management cautions when applying are collected in Detailed Guide to the K Program and Advanced Technology Development Support. For how university-originated research relates to this support and to research security on both sides, please also see University Research Integrity and Economic Security.
Pillar 4: Non-Disclosure of Patent Applications
The final pillar is the regime that corporate IP staff most easily overlook, and yet its impact is large. Patents are, by their nature, published a set period after filing. But if even sensitive technologies that could lead to nuclear weapons or advanced weaponry were published to the whole world, that would become a hole in security. So this patent non-disclosure system was created to allow such inventions' patent applications to be kept non-public. Operation began on May 1, 2024.
The flow is as follows. The Commissioner of the Japan Patent Office forwards application documents that could be in scope to the Prime Minister. The Prime Minister conducts a "preservation examination" and, if judged necessary, makes a "preservation designation." Once a preservation designation is made, procedures such as publication of the application, the decision to grant a patent, and the decision of refusal are suspended, and disclosure of the invention's content is, as a rule, prohibited. Moreover, you cannot withdraw the application to exit the system. Falling within scope are the 25 "specified technology fields" defined by the enforcement order (each item of Article 12, Paragraph 1 of the Order) using the International Patent Classification. Camouflage and concealment of aircraft, autonomous control of unmanned aircraft related to weapons, guided weapons, electromagnetic pulse munitions, submersibles, semiconductor photodetectors with quantum dots or superlattice structures, protection of computer components by tamper-resistant housings, isotope separation of uranium and plutonium, nuclear explosive devices—fields whose sensitivity comes through from the names alone are lined up.
What makes practice tricky is that, of the 25 fields, the technologies in items (10) through (19) receive a conditional treatment: because their impact on industry is large, they are subject to preservation examination only when they fall under the "additional requirements" (Article 12, Paragraphs 2 and 3 of the Order). Does your invention merely touch a classification, or does it also satisfy the additional requirements? You need to discern this line before filing abroad. Penalties are also provided for under the system, and the more a company handles technologies that could fall within scope, the more indispensable a pre-filing check practice becomes. The list of the 25 fields, the additional requirements, the relationship with foreign filings, and the concrete pre-filing check procedure are explained—following the article numbers—in Detailed Guide to the Patent Non-Disclosure System.
Which Pillar Does Your Company Fall Under? A Practical Inventory
Having read this far through the four pillars, if you have started thinking "which one is us?"—you are on the right track. Responding to the Economic Security Promotion Act begins not with memorizing the statute, but with taking inventory of your own business against the four pillars. What I always ask of clients is to identify the following four points.
First, whether any specified critical materials are included among the goods you procure. Visualize your dependence on designated items such as semiconductors, storage batteries, critical minerals, permanent magnets, and fertilizers. Second, if your company is a core infrastructure business, who the contractors are for introducing and maintaining specified critical equipment, and whether you have a grasp all the way down to their sub-contractors. Third, whether the themes you are developing touch the specified technology fields of patent non-disclosure. Anything you are considering filing abroad especially warrants caution. Fourth, whether the solicitation areas of support systems like the K Program overlap with your own R&D themes. Include the offensive perspective in your inventory as well.
Once you actually do this inventory, many companies notice that "just one pillar" does not cover it. A semiconductor manufacturing equipment maker, for example, straddles multiple pillars—the first through materials procurement, the fourth through R&D on sensitive technology, and the third through state support. That is precisely why having the whole picture at the outset pays off. What comes into view during the inventory is the contiguous relationship with export control, which I discuss next.
The Economic Security Promotion Act and the Foreign Exchange Act / Export Control Are Two Sides of the Same Coin
The Economic Security Promotion Act and export control under the Foreign Exchange Act. There are quite a few companies that manage these two as separate things. But when you face them in practice, you realize the two are branches growing from the same root. Whereas the Foreign Exchange Act and export control regulate the scene of "sending your company's goods or technology outside," the Economic Security Promotion Act sits on the domestic industrial-base side—"securing critical goods, protecting infrastructure, nurturing technology, and keeping patents non-public." The direction is opposite, but what they deal with is the same sensitive technology and the same counterparties.
Let me name the specific scenes where they overlap. The work of determining whether your invention falls within a specified technology field of patent non-disclosure follows exactly the same mode of thinking as classification in export control (determining whether your company's goods or technology fall on a control list). The work of screening whether a core infrastructure contractor is trustworthy is contiguous with counterparty screening in export control (confirming that a trading partner is not a sanctioned or concerning party). The work of grasping the procurement sources of critical goods and visualizing your dependence is also shared as supply-chain due diligence. For the whole picture of classification, see How to Carry Out Classification; for counterparty confirmation, see Explaining Deemed Export Risk and The Complete Guide to Sanctions Lists.
Keeping this cross-cutting classification and screening running by hand, indefinitely, is not realistic. Both the classification determinations and the counterparty matching need to keep pace with the latest laws while leaving a record of their basis. The export control AI agent TRAFEED that we developed was built precisely for this area. It consolidates classification and counterparty screening in line with METI's standards, reflects updates to each country's laws and regulations, and visualizes the level of concern in a short time. We have confirmed classification accuracy of 95% or higher in joint demonstrations, including one with Okayama University (as of March 2026, in-house study). That said, the final classification and the decision on whether an export may proceed rest ultimately with your company's export control manager; think of TRAFEED as a tool that supports that judgment quickly and without omissions. Before you exhaust yourselves carrying economic security and export control separately, I recommend redesigning classification and screening as one contiguous whole.
Frequently Asked Questions (FAQ)
What is the Economic Security Promotion Act? Explained simply. Its formal name is the "Act on the Promotion of Ensuring Security by Taking Economic Measures in an Integrated Manner" (Act No. 43 of 2022). It was enacted on May 11, 2022 and promulgated on May 18, 2022. It is a comprehensive law for protecting national security from an economic standpoint, administered by the Cabinet Office. It comprises four pillars—securing critical goods, protecting core infrastructure, nurturing advanced technology, and keeping patents non-public—and it was enforced in phases from September 2022 to May 2024.
What exactly are the four pillars of economic security? The first is ensuring the stable supply of critical goods, the second is ensuring the stable provision of core infrastructure services, the third is support for the development of advanced critical technologies, and the fourth is the non-disclosure of patent applications. The response demanded of companies differs for each: subsidies, pre-screening, support, and non-disclosure.
Is my company subject to the Economic Security Promotion Act? The scope differs by pillar. Companies that manufacture or procure specified critical materials fall under the first, core infrastructure operators that introduce or outsource specified critical equipment fall under the second, and companies conducting R&D on sensitive technologies and considering foreign filings fall under the fourth. The starting point is an inventory of three things: procurement-dependent materials, the outsourcing partners for infrastructure equipment, and whether your R&D falls within a specified technology field.
Are there penalties if I inadvertently file abroad under the patent non-disclosure system? Inventions falling within the 25 specified technology fields defined by the enforcement order are subject to preservation examination and preservation designation, and disclosure of the invention or foreign filing is restricted. Penalties are provided for under the system. Companies handling technologies that could fall within scope cannot do without a practice of checking, before filing abroad, whether their invention falls within a specified technology field.
How does the Economic Security Promotion Act differ from export control (the Foreign Exchange Act)? The Foreign Exchange Act and export control regulate the moment goods or technology leave the country, whereas the Economic Security Promotion Act sits on the domestic industrial-base side—securing critical goods, protecting infrastructure, and so on. Yet the two are contiguous when it comes to sensitive technology and counterparty screening, and the practical work of classification and counterparty screening is shared. In practice, a mindset of designing the two in an integrated manner—rather than managing them separately—pays off.
Summary
The Economic Security Promotion Act will always get you lost if you try to understand it all at once. Finally, let me organize the key points to return to when you lose your way.
- Its formal name is the "Act on the Promotion of Ensuring Security by Taking Economic Measures in an Integrated Manner" (Act No. 43 of 2022). It is administered by the Cabinet Office and was enforced in phases from September 2022 to May 2024.
- The four pillars are: the first, strengthening the supply chains of critical goods; the second, stable provision of core infrastructure; the third, support for advanced technology development (the K Program); and the fourth, non-disclosure of patent applications. Their aims, jurisdiction, and required corporate response are all different.
- The starting point for corporate response is an inventory of four points: procurement-dependent materials, the outsourcing partners for infrastructure equipment, whether R&D falls within a specified technology field, and the solicitation areas of support systems.
- Economic security response and the Foreign Exchange Act / export control are two sides of the same coin, and the practical work of classification and counterparty screening is shared.
This article is, ultimately, a map. Once you can see which pillar your company is involved with, move on to each detailed guide and translate it into concrete procedures. On top of that, if you feel you cannot keep up with economic security response and export control while carrying them separately, starting with the consolidation of classification and screening is the shortcut. In an individual consultation on TRAFEED, we propose—matched to the current state of your organization—which of your operations will be most effective to automate first. Now that you have grasped the whole picture of the regime, I think it is just the right moment to start moving.