Foreign Influence in Japan: Lessons from the UK, US and Australia

Introduction

Japanese democracy has long been believed to be largely immune from foreign influence by virtue of cultural and language barriers. However, since 2012, and during the second administration of Prime Minister Shinzo Abe, concerns began to emerge that China was influencing Japanese public opinion through social media. Suspicions are now being raised about Russian influence, notably in connection to the upper house election of 20 July 2025.

The Policy Research Council of the Liberal Democratic Party submitted a proposal concerning the reinforcement of public security to the Japanese government on 27 May 2025. It suggested that the Japanese government should consider preparatory discussions for the implementation of an anti-espionage law that would be on a level similar to other countries’ laws. By drawing lessons from the experience of other countries with comparable political systems, the lessons from this paper could contribute to taking this proposal forward in Japan.

Since the Second World War, the Japanese government has sought to conduct national affairs in accordance with the pacifist principles enshrined in the present constitution. The Japanese people, under this constitution, have enjoyed peace while remaining sensitive to security-related legislation, as exemplified by the protests over security treaties in the 1970s. In light of this sentiment, and despite the challenges surrounding growing Chinese and Russian influence, the Japanese public and Japan’s democratic politics are currently not protected by legislation addressing foreign influence. This is the focus of the first section of this paper.

Meanwhile, as a result of facing similar threats, the US – Japan’s key ally – and like-minded countries such as the UK and Australia – have established their own legislation to deal with foreign influence. When considering the kind of legislation Japan could introduce to address this problem, there is merit in reflecting on the experience of like-minded partners – Japan shares similar democratic institutions and values with the UK, the US and Australia, and faces similar threats to them. These shared experiences are analysed in the second section of this paper.

As Japan faces growing efforts by foreign governments to interfere in its domestic affairs, it should consider the experience of allies and like-minded partners in developing legislation to monitor or control foreign influence in its politics. The purpose of this paper is to compare the effects of new legislation in the UK, the US and Australia with a view to the possible application of a similar system in Japan.

This paper was informed by interviews conducted between March and July 2025 with experts in academia and think tanks, along with serving officials from Australia.

Key Findings

• If Japan continues without effective legislation and operational mechanisms, it is likely that foreign adversaries will see this as an invitation to take advantage of Japan’s vulnerabilities.
   
• Overarching security legislation in a form similar to the UK National Security Act 2023 should be adopted, from which subsidiary legislation for countering foreign influence – as well as legislation for other problems, including counterespionage – could flow.
   
• This paper proposes a middle-ground approach, drawing elements from different countries to align with Japan’s legal and institutional framework, which could involve adopting a single-tier classification structure, while integrating national security considerations to capture sufficiently broad foreign activity.
   
• Japan should identify a single lead department to ensure coherence and consistency in the response to misinformation campaigns and related threats to subvert its democracy.

Japan’s Lack of Legislative Framework for Countering Foreign Influence

In an interview, Luke de Pulford, founder and executive director of the Inter-Parliamentary Alliance on China, asserted that the United Front Work Department of the Chinese Communist Party (UFWD) and its proxies represent an imminent threat to Japan, stating that ‘there’s no question about that’.1.  In light of his observations, and supported by recent reports by the UK–China Transparency charity on the United Front’s activities in the UK and the United Front serving as China’s ‘magic weapon’, China’s attempted influence over Japan is plausible and it seems reasonable to suspect that China is attempting to exert some degree of influence over Japan’s political sphere.

At the same time, Maya Sobchuk, visiting researcher in the Economic Security Research Program at the University of Tokyo’s Research Center for Advanced Science and Technology, indicated in an interview that Russia is also willing to influence democratic societies through information operations and invests considerable effort into producing information and messaging in the Japanese language.2.  Russia targets messaging in Japanese to influence the Japanese younger generation, in particular those in their teens and early 20s, especially using generative AI tools. These developments suggest that Japan could consider regulations that take such external threats and methods into account.

Between 2018 and 2025, the UK and Australia set up similar schemes to counter foreign influence. The US had already established similar lines in 1938. Although Japan is a member of the G7, and is strengthening its relationship with the UK and Italy on sensitive projects, such as the Global Combat Air Programme, as one of the UK’s ‘closest strategic partners, including on security’, it is yet to enact similar legislation. In fact, for most of its post-Second World War period, Japan had very limited counterintelligence legislation in general, a situation that has led to Japan being seen in the 1980s as a ‘spy haven’.

When it comes to countermeasures aimed at foreign interference, Japan has only a small number of existing laws and regulations such as the Act on the Protection of Specially Designated Secrets, the National Public Service Act, and the Self-Defense Forces Act. Such laws were essentially enacted to prevent the leaking of information obtained by national civil servants. While there is currently no legislation aimed specifically at deterring or preventing foreign interference, there has been growing attention towards the need for such laws and regulations.

As Japan’s growing strategic importance makes the country a greater target for influence, there is increasing awareness that its open, free and liberal society means it is vulnerable to exploitation by those seeking to exert foreign interference. Japan’s then-Deputy Chief Cabinet Secretary Kazuhiko Aoki indicated his recognition of this problem in a press conference on 16 July 2025, where he stressed that Japan is becoming the target of foreign interference in its election, through the dissemination of misinformation. In an interview with NHK One on 14 August 2025, Japan’s Minister for Digital Transformation Taira Masaaki also confirmed that Japan is becoming a target. On 5 September 2025, Chief Cabinet Secretary Yoshimasa Hayashi raised concerns about an increasing threat of influence operations, and announced that he is aware that Japan ‘needs to enhance countermeasures’.

The Constitution of Japan and the laws that flow from it protect the freedom of media and expression. Despite concerns regarding foreign interference in elections, Japan’s legislature remains cautious when it comes to regulating the media, and the Japan Newspaper Association itself vehemently opposed the 2002 Act on the Protection of Personal Information. In light of recent interest in managing the influence of social media in elections, the Japanese government is reviewing its legal framework, including the Information Distribution Platform Act. The latter is a response to illegal and malign information on the internet but is not intended for foreign influence activities.

In summary, despite being a probable target of foreign influence operations, and making efforts to keep up with the development of the threat, Japan still lacks a comprehensive legislative apparatus to combat foreign influence and lacks certain tools in the field of counterintelligence.

Comparison of the Foreign Influence Registration Scheme Across the UK, the US and Australia

Before examining individual country cases, it is important to clarify the distinction between the notions of foreign state ‘interference’ and ‘influence’. The non-intervention principle is generally accepted as the corollary to the right to sovereignty, territorial integrity and political independence in international law. Yet, there is currently no widely accepted definition of ‘foreign interference’ in international law.

According to Charles Parton, Senior Associate Fellow at RUSI, the Council on Geostrategy and MERICS, former Australian Prime Minister Malcolm Turnbull framed interference as ‘covert, coercive, [and] corrupting’. Consequently, ‘foreign interference’ by states could be characterised as ‘covert’ (the state perpetrating the activity is concealing its identity), coercive or corrupting, or a combination of two or three of these criteria.3.  In an interview, Sam Dunning, Director of UK-China Transparency and a RUSI Associate Fellow, cited the UK 2023 National Security Act (NSA), in which some defining elements framed foreign interference as a ‘coercion’ activity.4.  In either case, ‘interference’ – unlike ‘influence’ – is regarded as malign activity perpetrated by hostile states. Indeed, by comparison, the UK Foreign Influence Registration Scheme (FIRS) defines ‘political influence’ activities as any ‘communication, public communication or provision of money, goods or services intended to influence a political matter’. This paper has a particular focus on foreign interference. As the UK has most recently developed its FIRS legislation, this paper first examines its framework, before examining those of the US and Australia.

The UK FIRS Approach

The UK launched its FIRS on 1 July 2025, as a new component of the 2023 NSA. The impetus for this policy initiative can be traced back to concerns of foreign interference during the 2016 Brexit referendum and the 2019 general election. A 2021 report by the UK Parliament’s Intelligence and Security Committee found that ‘the UK is clearly a target for Russia’s disinformation campaigns and political influence operations and must therefore equip itself to counter such efforts’. In 2022, the Security Service (or MI5) issued an alert concerning the activities of a UK-based lawyer named Christine Ching Kui Lee, suspected to have been engaged in ‘political interference activities’ for the Chinese state, highlighting that a similar threat of interference was posed by China. Lee brought a legal challenge against MI5 following the alert, which she lost.

The UK NSA was enacted on 11 July 2023 after being examined in 18 sessions in Parliament between 2022 and 2023. The government of the day, led by Rishi Sunak, was conscious of the need to enhance resilience to tackle the new types of threats mentioned above. The Act consists of six parts, including ‘espionage, sabotage, [and] persons acting for foreign powers’. Under ‘Part 4’, which covers the ‘foreign activities and foreign influence registration scheme’, the provisions for FIRS are set out under the remit of the Home Office. According to a Home Office statement, FIRS is designed first to ‘shed light on’ foreign state interference by increasing the transparency of foreign activities. Second, it ‘gives the police and MI5 a critical new disruptive tool, [including] criminal offences for those who fail to comply with the scheme’. The third aim is deterrence: ‘those who seek to harm the UK … will face a choice – either [to] tell the government about their actions, or face arrest and imprisonment’.

FIRS would not inherently prevent a person or organisation from engaging in political activities on behalf of foreign states, but rather, requires the registration of activities in one of two tiers: ‘political influence tier’ and ‘enhanced tier’. The range of activities that an actor must declare that they are undertaking on behalf of the foreign entity, and the severity of the penalty for failure to make the declaration, depend on which tier the state directing the influence has been placed under by the UK government. In the ‘enhanced tier’, the person or organisation under the guidance of the specified foreign state must declare broader areas of their activities than would be the case under the ‘political influence tier’, for the purpose of protecting UK interests. In both tiers, any individuals or entities working for a foreign state in the UK are required to register and declare their activities, or they could face legal action and imprisonment.

The two-tier system involves a judgement about the intent of influence by certain countries. According to UK government guidance, the enhanced tier is designed to ‘provide greater assurance around the activities linked to certain foreign powers, or foreign power-controlled entities, which may pose a greater risk’. Before implementing the scheme, the UK minister for security announced in a statement that Iran and Russia would be placed in the ‘enhanced tier’.

A petition in October 2025 arguing that China should be included in the enhanced tier gathered close to 6,000 signatures, reflecting a sentiment echoed by de Pulford, who assessed that Chinese ‘influence’ is greater than that of other countries and has a malign intent.5.  De Pulford especially emphasised that the threats posed by China are of greater concern to the UK than those posed by Iran, and referred to the 2022 joint address by MI5 and FBI heads, which warned of the growing threat posed by China. In his assessment, Iranian activity in the UK is small compared with that of China. In view of the threats posed by Chinese state organisations, such as the Ministry of State Security of the People’s Republic of China and the UFWD, interviewees agreed that the FIRS regime should mitigate foreign interference from China as well as Iran and Russia.6.

UK government officials have expressed similar views. In a threat update provided to the UK on 8 October 2024, MI5 Director General Ken McCallum mentioned the imperative of ‘tackling threats aimed at our democracy’ that are initiated by China. The UK’s 2025 National Security Strategy judged that ‘instances of China’s espionage, interference in our democracy and the undermining of our economic security have increased in recent years. Our national security response will therefore continue to be threat-driven, bolstering our defences and responding with strong counter-measures’. The recent cases of Yang Tengbo and Lee – both alleged Chinese agents – demonstrate China’s efforts to infiltrate UK political circles.

And yet, China is not currently included in the UK’s enhanced tier. Moreover, then-Foreign Secretary David Lammy’s statement from June 2025 on the China Audit (claiming to take ‘the world as it is, not as we would wish it to be … Never compromising on our national security’) was all but silent on these themes of espionage, influence and interference.

The UK’s current trade status with China means that placing China in the FIRS’ enhanced tier would risk offending Beijing, thus forcing the current UK government to make a difficult trade-off across national interests. Moreover, in terms of its intended purpose, as envisioned by the previous government, the FIRS would be less effective if the system goes ahead in its current form. According to the experts interviewed for this paper, the FIRS legislation is weakened by the fact that China is not included in the enhanced tier.7.  If the legislation had made the type of influence, rather than the country, the decisive criterion, it would have been possible to treat all countries in the same way, and avoid the need to make a painful trade-off. If the tiers are considered essential, countries should be added in the appropriate tier regardless of trade considerations.

The UK’s FIRS, enacted as part of the NSA, is characterised by its attempt to enhance transparency regarding foreign interference, grant new powers to law enforcement and strengthen deterrence. At the same time, its adoption of a two-tier system has drawn criticism, particularly over which countries are placed in the enhanced tier.

The US Foreign Agents Registration Act

The US enacted the Foreign Agents Registration Act (FARA) in 1938. It falls under the remit of the FARA Unit (part of the National Security Division). The FARA requires anyone acting on behalf of a foreign country to register to make their political activities public. Otherwise, anyone who violates any provision of the Act could be vulnerable to legal action and punishment, as observed from examples of recent cases. This longer history of enactment in comparison with the UK has provided a wealth of precedents.

When it was established, the FARA was designed to require the disclosure of foreign political activities that could influence the US government. The UK FIRS system was designed with this Act in mind, and initially, the US government it as a tool to control the domestic influence of lobbyists.

The interpretation of the Act has evolved over its long history. From the perspective of public diplomacy and propaganda studies, Nancy Snow, an expert based in Japan, highlighted in an interview that both the FARA and the FIRS are designed to shine a light on foreign interference by making actors identify themselves, in order to enhance public awareness.8.  The US government has recently sought to charge some foreign-based actors with breaking the Act; for example, the first administration of President Trump ordered two Chinese state-run media outlets to be registered under the FARA.

As with other systems designed principally to deal with lobbyists in the home jurisdiction, the application of the FARA faces challenges and is less effective when applied to the actions of foreign actors overseas who are trying to affect US politics. Nevertheless, the Act is being applied to individuals beyond US soil in ways similar to the approach developed to countering malign cyber activities. Although it requires that registered agents identify and label their information materials, anyone engaging in activities outside the US is less likely to comply with the law, particularly those who are attempting illicit interference.

Thus, further legislation is needed in the US to tackle actions where new forms of media (especially social media) are enabling foreign actors to influence domestic media from overseas. Perhaps the most pressing concern is the social media service TikTok, which has been accused of collecting personal data and to providing it to the Chinese government, which could use if for any purpose. In turn, there has been an ongoing debate in the US about whether TikTok constitutes a threat to national security, for which there would be scope to apply the FARA. For the moment, Trump has issued an executive order delaying the enforcement of action against TikTok. Even if the Chinese company ByteDance were to sell its US branch of TikTok to a US company, it is still likely there would be scope to apply the FARA to it, as long as TikTok remains under the control of ByteDance.

Like the FIRS, which drew from elements of the FARA as inspiration, the FARA seeks to shed light on and address foreign interference. However, as with any other legal framework, the FARA is not without challenges, and updates are needed to ensure it remains relevant to the current circumstances. In particular, it requires revision to reflect recent developments, such as the rise of social media.

Australia’s Foreign Influence Transparency Scheme

The Australian approach to addressing foreign interference is the Foreign Influence Transparency Scheme (FITS). It commenced in December 2018 under the legislation of the Foreign Influence Transparency Scheme Act 2018 (FITS Act) and is administrated by the Attorney-General’s Department. The FITS is designed to improve the transparency of any activities conducted to achieve political or governmental influence. The FITS Act describes offences for non-compliance which are subject to prosecution, as does the UK’s FIRS and the US’ FARA. Australia’s FITS (and the US’ FARA) differ from the UK’s FIRS mainly in registration requirements: unlike the FIRS, the FITS and the FARA do not adopt a two-tier system and are instead applied uniformly.

The FITS also faces certain challenges. Although it has been almost seven years since the scheme began, over 600 activities have been registered at the time of writing. While an average of around 100 cases a year may not seem a particularly large number in comparison with over 500 active registrants under the US’ FARA, since the legislation was introduced, the government has experienced challenges in administering the scheme. One has been how to encourage individuals and entities to comply with the FITS’ obligations, as there are limited enforcement options. The only enforcement mechanism available is criminal prosecution, which is reserved for the most serious cases, creating a high bar for action.

In June 2024, Australia’s Parliamentary Joint Committee on Intelligence and Security completed a review of the 2018 FITS Act with an eye to reforming the scheme. According to the review, there are complexities in the way the FITS defines a foreign government-related entity and a foreign government-related individual. Moreover, the current Australian government also supports Recommendation 9 from the review, which calls for the definition of the key term acting ‘on behalf of’ a foreign principal in the FITS Act be clarified. Similarly, Snow highlighted that the FARA’s definition of ‘political activity’ in the US is also unclear.9.

Australia’s experience illustrates the challenge posed by creating exemptions from the legislation, such as those for commercial or business pursuits. The Attorney-General’s Department outlined in one of its submissions to the Parliamentary Joint Committee in Intelligence and Security some of the difficulties associated with creating exemptions under the FITS Act. The department noted that ‘certain exemptions do not have a clear justification, have unclear scope, or lead to inconsistent outcomes for similar relationships … The cumulative effect of the exemptions substantially narrows the scope of the Scheme’. When establishing exemptions, it is important to carefully define their scope. If legislation indeed allows for areas of exemptions, these risks increase the complexity of the scheme’s implementation and make it less effective.

Unlike the UK’s FIRS, Australia’s FITS adopted the single-tier system in order to apply it equally. Still, although not much time has passed since the FITS was introduced, the scheme already faces some challenges, such as ambiguity in the definition of terminology, questions about appropriate exemptions, and how to encourage people to register.

Lessons from Experiences of the UK, the US and Australia

Before examining the case of Japan, it is necessary to summarise the positive and negative lessons from each of the countries studied. Although each country has its own legislation, there are points in common. One key issue is the shared intent in the legislation to mitigate the effect of foreign interference by increasing the transparency of foreign activities. In addition, each of the three countries has adopted the approach of creating an instrument for enforcement pursuant to legal action; for example, if an actor violates the laws, they are liable to be punished. This, in turn, functions as a deterrent. Another lesson is that having created a legal basis for action, it is also vital to clearly designate which ministry is responsible for its operation. For example, in the UK, the FIRS is a part of the NSA and therefore under the remit of the Home Office.

A further crucial lesson from the experience of the UK, the US and Australia is how to identify the targets of the legislation. The UK’s FIRS has a two-tier system that requires the government to choose which country should be designated in the enhanced tier. On the other hand, the US’ FARA and Australia’s FITS have a single tier system, which makes it easier to treat every country equally, and avoids the diplomatic complication of singling out countries.

Next, the US’ experience poses the question of extra-territoriality. The FARA faces notable challenges in being applied to the actions of foreign actors undertaken from overseas. Anyone engaging in activities outside the US, who intends to affect US policy, is less likely to comply with the law because of the lack of means to enforce it. This increasingly concerns interference via social media.

The case of Australia highlights the need to consider the practicalities of ensuring compliance with the legislation, since its FITS faces obstacles in encouraging persons or organisations to register. Furthermore, the FITS has some ambiguity in its definition so that it captures a broad range of actions, and its range of exemptions narrow the scope of implementation.

Best Practices Against Foreign Influence for Japan

As examined thus far, the UK, the US and Australia have responded to the problem of foreign influence by developing individual legislative approaches, each with their own shortcomings. Taking specific national security needs into account, Japan will not necessarily exactly align itself with the approach taken by other countries. Nevertheless, there may be areas where the experience of others can be informative.

In October 2022, a question in two parts was raised by a member of the Japanese Diet regarding plans for Japanese legislation in this field. First, Kamiya Sohei, leader of the political party Sanseito, enquired whether the Japanese government had considered establishing a law that would have the same effect as the FARA or the FITS, and if so, what the status was for such a process. The second part requested clarification on whether the government recognised the need for such legislation and queried its future policy. At the time, Prime Minister Fumio Kishida’s administration answered that it was difficult to respond to the question, as its meaning was not clear. Nonetheless, Kishida added that the Japanese government perceived the importance of preventing misinformation and dissemination activities aiming to expand foreign interests and expressed his government’s determination to make the necessary efforts against foreign interference with the relevant ministries.

As noted above, legislation related to security issues can be contentious in Japan. After the Abe administration took a cabinet decision on the ‘Development of Seamless Security Legislation to Ensure Japan’s Survival and Protect its People’ in July 2014, there were huge protests around the National Diet building in Tokyo. The interpretation of Japan’s post-war constitution, particularly centred on Article 9, was the subject of debate. This is because Article 9 sets out the principles of Japan’s renunciation of war and denial of the right to belligerency. Similar debate may arise when it comes to devising legal measures to prevent foreign influence in Japan.

Although Japan has a national security council and a national security strategy, Japan has no national security act that could provide a basis for downstream FIRS legislation, unlike the UK, the US and Australia. It may therefore be more difficult to enact legislation to mitigate foreign interference without creating a broader legislative apparatus for security. A first step would be to enact an underlying law such as the UK’s NSA before proceeding further. In enacting the law, as de Pulford emphasised, it is preferable for Japan that the provision of a law similar to the NSA should be broad enough to tackle malign activity.10.  In any case, since this would be Japan’s first postwar system designed to address counterintelligence directly – including foreign interference – it will inevitably involve contentious debate.

Nevertheless, if Japan could enact such a law in the future, particularly where the law is designed to serve as a comprehensive framework for countering malign influence and counterintelligence, relevant specific legislation and procedures would follow from it.

When it comes to placing a country into the specific categories of a two-tier system, as with the UK’s FIRS, the question of which country to designate may prove so divisive in Japan that it would threaten to not only obstruct progress on countermeasures, but also to bring the entire debate to a standstill. Considering the current relationship between Japan and other countries that are likely to be a source of influence – especially neighbouring countries – it is indeed inadvisable to adopt a two-tier system. The impression that Japan is targeting a specific country could foster distrust of Japan among other nations, with results no less controversial than those in the UK. Adopting a multi-tier system would further introduce delays in adopting similar legislation and result in implementation problems. To avoid this, the Japanese government could consider treating all countries equally, building on the experience of the US and Australia.

In the US, the FBI’s Foreign Influence Task Force coordinated with the FARA Unit. However, this unit was disbanded in early 2025 when the US government decided to restrict the application of the FARA. The experience of Australia further strengthens the idea of having a strong lead organisation, since the FITS is administrated by the Attorney-General’s Department, which works closely with other relevant agencies – including the National Intelligence Community – which are jointly responsible for Australia’s resilience framework to counter foreign interference. In other words, in the UK, the US and Australia, operations are handled by the relevant government ministry, and the actual investigations and related work are carried out with the support and cooperation of the intelligence and security services.

When considering introducing a similar system in Japan, the question of which authority would take charge inevitably arises. At present, multiple ministries and agencies are involved in responding to misinformation campaigns, resulting in a lack of coherence and consistency. Although collaboration across departments is necessary, the involvement of a single lead department – for example, the Home Office, in the UK – is critical to ensuring clear responsibility and an effective approach. The UK’s MI5, which described the FIRS as ‘essential’ for Britain’s national security, is expected to cooperate with the Home Office.

Conclusion

As the 2022 National Security Strategy of Japan highlighted, Japan is now facing 'the most severe and complex security environment since the end of WWII’. In that sense, Japan needs to urgently prepare for 21st-century threats. Despite the fact that legislation on national security remains a sensitive issue for the Japanese public, allegations of foreign interference (including in elections) continue to mount, building the justification to more urgently consider necessary measures. Indeed, if Japan has no effective countermechanisms and legislation, adversaries will take advantage of the country’s vulnerabilities.

Consequently, it would seem necessary to secure the effectiveness of enforcement, potentially through criminal prosecution like the UK’s FIRS, the US’ FARA and Australia’s FITS. This paper proposes that adopting a middle-ground approach with a single-tier classification structure – like the FARA and the FITS – while integrating national security considerations (as seen in the FIRS) to capture sufficiently broad activity would align more closely with Japan’s legal and institutional framework. Japan’s response to the problem of foreign influence should strike a balance between the imperatives of enhancing transparency, and of providing deterrent capabilities.

Most Japanese citizens understand that, as Sun Tzu observed, ‘supreme excellence consists in breaking the enemy’s resistance without fighting’. Therefore, to make the world a safer place, Japan must consider its own way of handling the threat of foreign influence. If this paper contributes to further examination of this question, it would be a most welcome and unexpected outcome. Considering the importance of gaining public understanding for legislation that touches on civil rights and freedoms, this paper can serve to raise greater public awareness of the need to address the danger posed to those values by a growing threat of malign foreign influence.

About the Author

Naoki Tekada was a Visiting Fellow from 2024 to 2025 working in the Indo-Pacific programme of RUSI’s International Security Studies research team.