Economic Security for the Side Applying to Government Programmes: Telling a Real Barrier from a Soft One

Hello, this is Ryuta Hamamoto from TIMEWELL.

The night before a KAKENHI deadline, the submit button stops working. The research plan is finished. The budget table is in order. It still will not go through. The cause is that one co-investigator never ticked a single checkbox on a screen in e-Rad.

This is how applications for public research funding are actually failing right now. What makes it awkward is that among the requirements that have piled up around economic security, telling which ones are physical barriers of that kind and which are aspirations takes reading the primary sources. Brace for all of them as selection criteria and you spend time on preparation you did not need. Take them lightly and you cannot submit.

Explanations of this area already exist, written scheme by scheme and dug deep, and the overall shape of the regime is laid out in research integrity and research security: a complete guide. What is missing is the horizontal view. Which of these lands on us, and which does not. That is all this piece is about. The readers I have in mind are not the people inside universities but the ones going after government programmes from outside them: colleges of technology, prefectural research institutes, corporate R&D divisions, startups, and the administrative, corporate planning and legal staff who actually assemble the application.

No scheme explanations here, just how each one lands

Let me clear up one premise first. The economic security requirements are not one scheme that gradually widened its scope. They are separate schemes stacked on top of each other, with different competent ministries, different laws and different kinds of obligation.

What took effect on 1 May 2022 was the clarification of so-called deemed export controls, through an amendment to the services notice under the Foreign Exchange and Foreign Trade Act. It sits with the Ministry of Economy, Trade and Industry, and the amending notice was promulgated on 18 November 2021¹. It is often described as the scheme that brought universities into scope, which is not accurate. The scope is "exporters and others", and companies and universities have carried the same obligation from the same day¹. How to read the three specific categories themselves is in understanding deemed export "specific categories" in five minutes, so I will not repeat it.

On 17 May 2024, the critical infrastructure scheme under the Economic Security Promotion Act (Act No. 43 of 2022) began operating. The Cabinet Office states explicitly that operation of the scheme started on Friday 17 May 2024². For what the scheme requires, see what is the critical infrastructure pre-screening scheme; for the fact that the Promotion Act itself is a composite law built on four pillars, see the Economic Security Promotion Act on one page.

On 16 May 2025, the Act on the Protection and Utilisation of Critical Economic Security Information (Act No. 27 of 2024) came into full force³. This is Japan's security clearance scheme. The wording matters here: it does not impose a uniform obligation on businesses generally. It is a voluntary framework in which, on the basis of a contract with and certification by a government agency, a business becomes a certified business able to handle the state's critical economic security information. I set this out in what the security clearance scheme is.

Why do these three get conflated? Partly because the Economic Security Promotion Act itself passed on 11 May 2022. With the enforcement on the Foreign Exchange Act side and the passage of the Promotion Act falling in the same month, memory turns them into one thread. And partly because, from the applicant's side, they arrive without being distinguished. Three legislative lineages still end up lined up as a table of requirements on a single sheet of application guidelines.

Seen from the applicant's side, this is how the three show up.

Scheme (effective date)	Basis and ministry	How it appears to an applicant
Clarified deemed export controls (1 May 2022)	Foreign Exchange Act, services notice (METI)	Situations where you must identify participants' specific-category status and have declaration forms and internal rules ready
Critical infrastructure scheme (17 May 2024)	Economic Security Promotion Act (Cabinet Office)	Notification if you are a designated operator. Situations where most applicants are on the other side, asked for information as a supplier or contractor
Security clearance (16 May 2025)	Critical Economic Security Information Act (Cabinet Office)	Situations where certification as a business, or naming of cleared personnel, is a precondition in government contracts and procurement

If you would like to measure where your own organisation stands on the export control side first, our export control compliance check will tell you, and the second half of this piece lands more concretely once you have.

Sorting requirements by the force behind them

Saying "you cannot win funding without doing this" overstates matters, but it is not a lie either. The requirements split into three layers by force, and each bites in a different way. Mix them up and you get the priorities wrong.

The first layer is a genuine hard gate. The FY2026 KAKENHI application guidelines state that where the principal investigator or a co-investigator has not registered their pledge status regarding research integrity with their institution in e-Rad, the application cannot be made⁴. JST moved earlier still, stating in a notice of 2 June 2023 that without the registration the application cannot be completed in e-Rad, and that all principal co-investigators are covered too⁵. The practice began with the FY2025 call⁶. The failure I described at the top is this one. For what to register and where, declaring conflicts of interest and conflicts of commitment walks through it down to the screen, so open that rather than have me repeat it.

One scheduling point to hold onto. The handshake between e-Rad and the electronic application system takes 30 to 60 minutes normally, and several hours when it is busy⁷. Contacting a co-investigator on the day of the deadline does not work. This is not about understanding the rules.

The second layer is sanction after the fact. Where there are statements at odds with the facts, or where a researcher failed to report to their institution in breach of the pledge, the project may be rejected, its selection revoked, or the award reduced⁸. You can still submit; it bites later. The measures, including the periods of restriction, are set out against the annexes in the same piece on declaring conflicts of interest.

The third layer is the one I most want to get across. Confirmation of organisational arrangements is not a barrier to applying. The KAKENHI guidelines provide that from FY2025 grants, where you plan to provide goods or technology subject to export controls under the Foreign Exchange Act, the presence of an export control system at your institution is confirmed at the payment application stage using what is registered in the e-Rad institution information⁴. What matters is that the guidelines do not say "no system, no payment". For research integrity arrangements the wording goes no further than saying enquiries may be made of the institution where necessary⁴.

So you do not need to brace for this the way you do for the first layer. To avoid any misreading, though: the export control system itself exists as a separate obligation under the Foreign Exchange Act. Saying it is not a barrier to the application is not saying you do not need it. How an institution builds that function from nothing is set out in building a research security function in 90 days.

Only the first layer sits on the deadline. Do not get that one backwards.

Establishing what does not apply is also part of the job

In December 2025 the Cabinet Office published its procedures document for securing research security⁹. It contains a heavy framework of thirteen due diligence items, and plenty of people who read it took away the impression that all of it has to be done in order to apply for public research funding. That is not the case.

The scope is limited to programmes designated as specified research and development programmes by the competent ministry in consultation with the funding agency. Turn that around and the FY2026 KAKENHI application guidelines do not contain the phrase "research security" even once⁴. The idea that research security arrangements have become a selection criterion across all public research funding is simply wrong. Which programmes are designated is worked out from the source text in research security became a funding condition in FY2026.

Let me be precise about force as well. The procedures document is guidance, not law. It writes restrictions on future applications for breaches in the future tense, as something that may be considered, and an amendment to the Guidelines on the Proper Execution of Competitive Research Funding that would ground it cannot be confirmed as of July 2026. The most recent amendment of those guidelines remains that of 17 December 2021, with no reference to the procedures document⁸. In practice, though, it works through a different route. Guidelines for designated programmes already carry the restriction measures in writing. JST's FY2026 call document states that for a breach of the procedures document, in light of how improper the conduct was and how serious its consequences, the conduct is treated as wrongful receipt under the Guidelines on the Proper Execution of Competitive Research Funding, and that restrictions on applying to the programme may be imposed on the researcher concerned and on any researcher who conspired with them¹⁰. Even where the guidelines themselves say nothing about the procedures document, as long as you are applying to one of those calls, it operates as a condition of the call. Still prospective as a scheme, already real in the call in front of you.

The line between what is required and what is merely desirable is also worth holding onto. What the procedures document requires is the thirteen-item due diligence on the principal investigator, research participants and co-principal investigators, plus confirmation of contract terms. Due diligence on a partner institution itself, and on supporters, is treated as desirable⁹. Get that backwards and you spend effort on investigation nobody asked for. How to gather and answer the thirteen items in practice is covered in how to complete a research security questionnaire.

Two details as well. The checklists in Annex 2 of the procedures document are sometimes described as two forms, one for the lead institution and one for researchers. There are in fact three, with a separate form for partner institutions⁹. If you expect to be named as a partner institution, plan on the basis that a form exists for you to complete. And the list of critical technology areas cannot be confirmed as having been drawn up or published as of July 2026. Until then the twenty technology areas in the basic policy on promoting research and development of specified critical technologies, adopted by cabinet decision on 30 September 2022, are used in its place⁹.

Let me state where this piece stands, once. The purpose of due diligence is to establish the fact of whether an entity appears on a list, and to adjust the design of a collaboration or a transaction where that is warranted. Appearing on a list is a regulatory designation, not a finding that the company or institution did anything wrong. This is not a procedure for treating listed entities as dangerous counterparties, and that premise is worth sharing.

Which of these lands on your organisation

The schemes above are almost always explained with university researchers or university administrators as the assumed reader. But universities are not the only ones going after these programmes, and the place where each type of applicant gets caught differs.

Colleges of technology sit on the same side as universities

Colleges of technology fall within KAKENHI's four categories of eligible research institutions. Those four are universities and inter-university research institutes; facilities attached to the Ministry of Education that carry out academic research; colleges of technology; and institutions designated by the Minister of Education⁴. Research integrity and e-Rad registration obligations apply exactly as they do to universities. The request issued by the Ministry of Education on 8 March 2022 on strengthening export control at universities and research institutions is addressed to the heads of colleges of technology as well¹¹. The ministry's research security help desk, set up on 10 April 2025, also covers universities, junior colleges, inter-university research institute corporations and colleges of technology¹². It is safest to design on the basis that colleges of technology sit on the same side as universities.

High schools cannot be explained with the same framework

High schools, by contrast, do not fall within the first three of the four categories⁴. The guidelines note that an institution outside those three must first obtain designation by the Minister of Education to become an eligible research institution, so the fourth category is a route that remains open. Either way, this does not mean high schools are not participants in large national programmes. Frameworks worth hundreds of billions of yen exist, such as the fund for promoting reform of upper secondary education, where schools and boards of education each carry part of the application work. Being honest about the limits of what I checked: I could not confirm primary sources on how research integrity or research security obligations are treated when a high school applies to a government programme. The framework above cannot be applied to explain it. Read the eligibility definition in each set of guidelines, and where the answer is not clear, check with the responsible office.

Prefectural institutes appear explicitly in eligibility rules

Prefectural research institutes are a category set out explicitly in eligibility rules. AMED's guidelines include prefectural research institutes among eligible applicants¹³. Where the category is listed, the research integrity provisions apply as they do to universities. At application, researchers declare the status of all research funding applications and receipts including those from outside Japan, and all affiliations and positions, and register in e-Rad their pledge to report to their institution¹⁴. In practice, the starting point is completing institution and researcher registration in e-Rad and getting the pledge registered for every participating researcher. One unregistered person still blocks the application.

Companies face requirements from two directions

Companies face requirements from two directions. On the public funding side, AMED's eligibility rules include corporate R&D divisions and technical research associations¹³, and there the research integrity obligations match those of universities. On the export control side, deemed export controls have applied to companies on the same terms as universities since 1 May 2022¹. A common misreading concerns the ministerial ordinance on compliance standards for exporters: establishing and carrying out a procedure to confirm the end user in addition to the end use is a compliance standard in itself, not an endeavour obligation. What was newly added as an endeavour obligation is the item on guidance to subsidiaries¹⁵. If you are starting with neither a dedicated officer nor internal rules, building an export control system from scratch in ten steps and choosing among the CISTEC model CP patterns are the practical routes. You do not have to draft the rules from nothing.

Startups keep resubmitting their capital structure

For a startup, the heaviest item is probably disclosure of the capital structure. The force here comes in two steps, so take them in order. What the procedures document lists for a partner institution itself is four things: the purpose of the collaboration, its track record in the relevant field over the past three years, its financial position and, where it is a company, its capital structure, and whether it appears on a list. The scope is limited to institutions other than universities, inter-university research institutes, colleges of technology, national R&D agencies and prefectural research institutes, and it sits on the "desirable to obtain self-declarations and carry out due diligence" side, meaning a measure whose implementation is not required at this point⁹.

Where the force changes is the funding agency's questionnaire. JST's template says that where the lead institution or a co-lead institution is not one of those categories, the financial position and capital structure, and whether the institution appears on a list, are to be submitted to JST. The examples given for evidence of capital structure are the annual securities report for a listed company, the shareholder register for an unlisted one, and a register of members for a foundation or NPO, in each case something from which major shareholders, their locations and their shareholdings can be established. And where those major shareholders change, resubmission is required each time¹⁶. For a company still raising rounds, this is not a one-off task. Plan on resubmission per round, and decide who owns that upkeep.

Contracts and procurement add a separate lineage

There is one route you will miss if you look only at research funding. Where you take on government contracts or procurement, a separate lineage of requirements is layered on top. That is the story in ISMAP and the SCS assessment scheme, and its lineage differs again from the three economic security schemes. The package for promoting government procurement from startups is widening the opening into public work, so it is closer to reality to assume that requirements come attached in proportion to how much the door has opened.

On the university side, the numbers show them catching up. According to a joint survey by the Ministry of Education and METI, the share of universities with internal export control rules in place rose from 66.3 per cent in FY2021 (212 universities) to 80.3 per cent in FY2024 (provisional, n=335), with all 86 national universities having them¹⁷. Note the denominator, though: national universities plus public and private universities with faculties in medicine, dentistry, pharmacy, science or engineering. Turn that around and the state of readiness at prefectural institutes, small and medium technical companies and startups is not visible as a figure at all. From the enquiries that reach me, organisations that discover the absence of internal rules only when they reach the application stage are concentrated outside universities.

Working backwards from the deadline

Last, the scheduling. Some things you can start once the guidelines are out. Some you cannot.

Registering the pledge in e-Rad is in the first group. The task itself takes minutes. What does not fit into the window is the coordination needed to get everyone, including collaborators, to spend those minutes. That is an organisational matter rather than a regulatory one, so there is no reason to wait for a call. Doing it today costs nothing.

The deemed export side takes much longer. One thing to establish first: whether a specific category applies has nothing to do with nationality. METI's Q&A states that the subject is any natural person who is a resident, regardless of nationality, and that Japanese employees, researchers and students are within scope for confirmation¹⁸. The research security procedures document likewise states that there must be no discriminatory treatment on grounds of nationality, race, religion or culture⁹. What follows is not a procedure for singling out foreign nationals. It is that whoever falls within a category goes through the same steps.

With that established, the steps. Before providing controlled technology to someone who falls within a specific category, you apply to METI's head office, the Security Export Licensing Division, for a service transaction licence¹⁸. Keeping that person away from controlled technology while the licence is pending is operational work: server permissions, where drawings are held, access to experimental data. Start thinking about it after filing and the research itself stops. Note that METI's Q&A states that a licence is not envisaged as being refused across the board merely because someone falls within a specific category, and that comprehensive licences are available¹⁸. Falling within a category is not the end of the road.

For people already employed as of 1 May 2022, no additional pledge needs to be obtained. There is a caveat, though. METI's Q&A says that if by any chance the content of that employee's past reports on secondary employment cannot be established, it needs to be confirmed afresh¹⁸. Skim past it as "existing staff are out of scope" and that check goes missing. For people not under your direction, such as students, research fellows, visiting teaching staff, emeritus professors and directors, adding a field to documents you would obtain in the ordinary course of business is enough: application forms, CVs, acceptance applications, collaboration agreements. Further investigation is not required¹⁸.

Where an application involves procuring equipment or joint implementation with overseas institutions, you may be asked to produce a classification certificate or a certificate of non-applicability. The differences between the formats are set out in how to write a classification certificate, and reading it before you need it is faster than looking it up under pressure. The contact points for when you are unsure are in the primary sources too. For questions on writing the specific-category confirmation procedure into internal rules, bzl-minashi-QA@meti.go.jp; for questions on application documents and how to complete them, bzl-qqfcbf@meti.go.jp¹⁸. There are plenty of situations where asking beats holding the interpretation inside your own organisation.

And writing all of this out, I keep thinking the same thing: expecting one person to track this volume by hand does not hold. The services notice keeps being amended, most recently by Export Notice 2025 No. 27, promulgated 14 November 2025 and effective 14 February 2026¹⁹. The End User List and the US Consolidated Screening List update on their own cycles. Application guidelines change every year, per programme. Any process built on reconciling all of it at each update will eventually miss something. How to hand that load to a machine is what I worked through in automating export classification with AI. TRAFEED, the service we offer, is an export control AI agent that reflects each country's regulations the same day and automates screening against sources such as the End User List and the Consolidated Screening List. To be clear about what it is: it is built on the premise that your own export control officer makes the final classification decision. It exists to leave time for the judgements a person should be making.

To sum up

The points, gathered up.

• The clarification of deemed export controls on 1 May 2022, the start of the critical infrastructure scheme on 17 May 2024, and the full entry into force of the Critical Economic Security Information Act on 16 May 2025 are three separate schemes with different laws, ministries and kinds of obligation. From the applicant's side they arrive as one table of requirements
• Only the first layer sits on the deadline. If the principal investigator or any co-investigator has not registered their research integrity pledge in e-Rad, the application cannot be made. The only way in is the affiliated institution tab, and the handshake takes 30 minutes to several hours
• The second layer is sanction after the fact; the third is confirmation of arrangements at the payment application stage. The third does not decide whether you can apply, so there is no need to throw a system together just before a deadline. The export control system is still an obligation under the Foreign Exchange Act, on its own timeline
• Research security due diligence is limited to designated programmes. Search the guidelines first and establish whether yours is designated. If it is not, the thirteen items need no preparation; if it is, investigating a partner institution itself remains desirable rather than required
• Colleges of technology fall within KAKENHI's four categories and are treated as universities are. High schools do not fall within the first three, so the same framework cannot simply be applied to them, though designation by the Minister of Education remains a route
• Prefectural research institutes, corporate R&D divisions and technical research associations all appear as categories in eligibility rules. Where the category is listed, the research integrity provisions apply
• Where you take on government contracts or procurement, requirements from the procurement side are layered on top, in a lineage separate from the three economic security schemes

One closing thought. Explanations in this area are overwhelmingly written for people inside universities, and the people who design the schemes are looking at universities first too. But plenty of applicants sit outside them. Prefectural institutes, local technical firms, a startup in its third year. An organisation heading into an application while assuming that none of this concerns them because they are not a university is, to me, the most exposed position of all.

Open the eligibility section of the guidelines and read whether your own category is listed there. That is the first check, and it takes five minutes. If you would then like to talk through building the export control side, please talk to the TRAFEED team. We start by laying the whole picture out again.

References and primary sources

Footnotes

1. METI, Trade and Economic Cooperation Bureau, notice amending the notice on transactions or acts providing technology requiring a licence under Article 25(1) of the Foreign Exchange and Foreign Trade Act and Article 17(2) of the Foreign Exchange Order, 20211102 Boeki-kyoku No. 1 / Export Notice 2021 No. 30. Promulgated 18 November 2021, effective 1 May 2022. Added specific categories (1) to (3), Annex 1-3 (guidelines for judging whether a specific category applies) and Annex 1-4 (example pledge). https://www.meti.go.jp/policy/anpo/law_document/tutatu/211118tsutatsu2.pdf ↩ ↩² ↩³

2. Cabinet Office, Director-General for Policy Planning (Economic Security), "Scheme for ensuring the stable provision of critical infrastructure services", stating that operation of the scheme began on Friday 17 May 2024. https://www.cao.go.jp/keizai_anzen_hosho/suishinhou/infra/infra.html ↩

3. Cabinet Office, Director-General for Policy Planning (Economic Security), Act on the Protection and Utilisation of Critical Economic Security Information (Act No. 27 of 2024). Passed 10 May 2024, promulgated 17 May 2024, in full force 16 May 2025. https://www.cao.go.jp/keizai_anzen_hosho/hogokatsuyou/hogokatsuyou.html ↩

4. Japan Society for the Promotion of Science, FY2026 Grants-in-Aid for Scientific Research application guidelines (Grant-in-Aid for Scientific Research A, B, C; Challenging Research (Pioneering, Exploratory); Early-Career Scientists), 14 July 2025. States that an application cannot be made where the research integrity pledge status is not registered in e-Rad; that from FY2025 grants the presence of an export control system is confirmed at the payment application stage from the e-Rad institution information; and the four categories of eligible research institutions (universities and inter-university research institutes, facilities attached to MEXT, colleges of technology, institutions designated by the Minister). The phrase "research security" does not appear in these guidelines. https://www.jsps.go.jp/file/storage/kaken_kiban_2025_g_3687/r8_7_kobo.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

5. Japan Science and Technology Agency (JST), notice on registering "research integrity" in e-Rad, 2 June 2023, stating that without the registration an application cannot be completed in e-Rad and that all principal co-investigators are covered. https://www.jst.go.jp/kisoken/boshuu/r05/teian/top/info/info_230602.html ↩

6. Japan Society for the Promotion of Science, FY2025 Grants-in-Aid for Scientific Research application guidelines (Specially Promoted Research, Grant-in-Aid for Scientific Research (S)), call opened 12 April 2024. First appearance of the e-Rad pledge as an application requirement. https://www.jsps.go.jp/file/storage/kaken_tokus2024/r7_4_kobo.pdf ↩

7. Japan Society for the Promotion of Science, KAKENHI electronic application system, guidance on entering research integrity information in e-Rad. States that the point of entry is the affiliated institution tab on the researcher information amendment screen in e-Rad, and that the handshake between e-Rad and the electronic application system takes time. https://www-shinsei.jsps.go.jp/kaken/docs/research_integrity_e-rad_touroku_2024koubo.pdf ↩

8. Agreement of the inter-ministerial liaison meeting on competitive research funding, "Guidelines on the Proper Execution of Competitive Research Funding", established 9 September 2005, amended 17 December 2021. Requires each ministry to state in its application guidelines that rejection, revocation of selection or reduction of the award may follow from statements at odds with the facts or from breach of the pledge. Restriction periods are in Annexes 1 and 2. These guidelines are an inter-ministerial agreement rather than law, and as of July 2026 the most recent amendment remains that of 17 December 2021, with no reference to the research security procedures document. https://www8.cao.go.jp/cstp/compefund/shishin_r3_1217.pdf ↩ ↩²

9. Expert panel on securing research security and research integrity (Cabinet Office, Bureau for Science, Technology and Innovation Policy), procedures document for securing research security, December 2025 (published 26 December 2025). Includes the thirteen due diligence items, the distinction between what is required and what is desirable, the three checklists in Annex 2 (lead institution, partner institution, researcher), the fact that self-declaration and due diligence on the four items concerning a partner institution itself (purpose of the collaboration, track record in the field, financial position and, for a company, capital structure, and whether it appears on a list) is a "desirable" measure applying to institutions other than universities and the like, and the use of the twenty technology areas in the basic policy adopted by cabinet decision on 30 September 2022 until the list of critical technology areas is drawn up. https://www8.cao.go.jp/cstp/kokusaiteki/integrity/yushikisha/guidelines_v1.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

10. Japan Science and Technology Agency (JST), FY2026 call document for the Strategic Basic Research Programs (CREST, PRESTO, ACT-X), call opened 7 April 2026. Under "(vi) Measures where a breach of the procedures document occurs", it states that a breach, in light of how improper the conduct was and how serious its consequences, is treated as wrongful receipt under the Guidelines on the Proper Execution of Competitive Research Funding (agreement of the inter-ministerial liaison meeting on competitive research funding, 9 September 2005), and that restrictions on applying to the programme and similar measures may be imposed on the researcher who wrongfully received funding and on any researcher who conspired with them. https://www.jst.go.jp/kisoken/boshuu/teian/koubo/2026youkou.pdf ↩

11. MEXT, Director-Generals of the Higher Education Bureau, the Science and Technology Policy Bureau, the Research Promotion Bureau and the Research and Development Bureau, request on strengthening export control at universities and research institutions, 8 March 2022. Addressed to the heads of national, public and private universities, colleges of technology, inter-university research institute corporations and national R&D agencies. https://www.mext.go.jp/b_menu/hakusho/nc/mext_00048.html ↩

12. MEXT, Director-Generals of the Science and Technology Policy Bureau and the Higher Education Bureau, notice on the establishment of the MEXT research security help desk, 7 Monka-ka No. 54, 10 April 2025. Covers universities, junior colleges, inter-university research institute corporations and colleges of technology. https://www.mext.go.jp/content/20250424-mxt_kagkoku-000039402_1.pdf ↩

13. Japan Agency for Medical Research and Development (AMED), FY2026 application guidelines for the flagship programme on overcoming intractable cancers, April 2026. Eligibility includes prefectural research institutes, corporate R&D divisions and technical research associations. https://www.amed.go.jp/content/000159002.pdf ↩ ↩²

14. Integrated Innovation Strategy Promotion Council, policy on securing research integrity against new risks accompanying the internationalisation and opening up of research activities, 27 April 2021. Provides that funding agencies require submission of the status of all research funding applications and receipts including those from outside Japan, and of all affiliations and positions, together with a pledge to report to the researcher's institution. https://www8.cao.go.jp/cstp/kokusaiteki/integrity/integrity_housin.pdf ↩

15. METI, ordinance partially amending the ministerial ordinance establishing compliance standards for exporters, METI Ordinance No. 79 of 2021, promulgated 18 November 2021 and effective 1 May 2022. Confirming the end user and improving the reliability of information are compliance standards themselves under Article 1, item 2(d), phrased as "shall carry out"; what was newly added as an endeavour obligation is guidance to subsidiaries under item 2(h). https://www.meti.go.jp/policy/anpo/law_document/shourei/20211118shourei.pdf ↩

16. Japan Science and Technology Agency (JST), research security questionnaire template (JST-TRUST), FY2026. Section 2, "Due diligence on the research institution", item (1), states that where the applicant's own institution (the lead institution) or a co-lead institution is other than a university, inter-university research institute, college of technology, national R&D agency or prefectural research institute, information on (i) financial position and capital structure and (ii) whether the institution appears on a list is to be submitted to JST. Footnote vi gives the examples of evidence for capital structure (annual securities report for a listed company; shareholder register for an unlisted company; a register of members or equivalent for a foundation or NPO) and states that where the major shareholders change, resubmission is required each time. The questionnaire is sent to candidate projects under designated programmes for which risk management has been judged necessary. https://www.jst.go.jp/osirase/research_security/pdf/rs_questionnaire_2026.pdf ↩

17. MEXT and METI joint survey on the share of universities with internal export control rules (66.3 per cent in FY2021 / 212 universities; 80.3 per cent in FY2024 / n=335, provisional; all 86 national universities in place. Denominator: national universities plus public and private universities with faculties in medicine, dentistry, pharmacy, science or engineering). The figures are those published by that joint survey, but the URL of the document carrying them could not be identified as of July 2026 (automated retrieval from the METI site is refused). Note that METI, Security Export Control Policy Division, casebook on security export control at universities and research institutions (responding to the clarification of deemed export controls), August 2023, is a collection of practices based on interviews with ten universities and does not itself contain the adoption figures. https://www.meti.go.jp/policy/anpo/daigaku/minashi.pdf ↩

18. METI, Security Export Control Policy Division, Q&A on the clarification of deemed export controls, revised 8 August 2023 (65 questions in total, with the cover noting that further revisions will follow). Includes that a licence is not envisaged as being refused across the board merely because a specific category applies; that comprehensive licences are available; that where the content of past secondary employment reports for someone employed as of 1 May 2022 cannot be established it needs confirming afresh; that for people not under the applicant's direction confirmation through documents obtained in the ordinary course of business suffices without further investigation; and the contact addresses. https://www.meti.go.jp/policy/anpo/law_document/minashi/minashiqa3.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

19. METI, notice on transactions or acts providing technology requiring a licence under Article 25(1) of the Foreign Exchange and Foreign Trade Act and Article 17(2) to (4) of the Foreign Exchange Order (services notice, 4 Boeki-kyoku No. 492, established 21 December 1992). The heading records the most recent amendment as Export Notice 2025 No. 27, promulgated 14 November 2025 and effective 14 February 2026. https://www.meti.go.jp/policy/anpo/law_document/tutatu/t10kaisei/ekimu_tutatu.pdf ↩