Key points

  • When tracking system trends, separate meetings into those that have completed revisions, those that inspect the implementation status, and those that are currently designing the system.
  • In July 2026, the revised Corporate Governance Code was finalized and its application began on the TSE. Therefore, the stage of following the revised expert meeting as a “meeting to create future rules” is over.
  • Important issues going forward will be sustainability assurance, corporate legislation, statutory disclosure, TSE's market segments/capital cost measures, and the establishment of acquisition practices.

First, divide it into three states.

The list of policy meetings becomes more difficult to understand as the number increases. In practice, it is helpful to categorize each meeting into three categories:

  1. Meeting that completed the system reform. Final documents and legislation are out, and companies are in the implementation stage.
  2. Meeting to check implementation status. Rather than creating new provisions, check whether the existing system is actually functioning.
  3. Meeting to continue system design. May create future obligations such as interim arrangements, exposure drafts, and legislation.

The main trends as of August 2026 are as follows.

policy flow Jurisdiction current status Recent achievements What to check next
Corporate Governance Code Revised Financial Services Agency/TSE Completed/Implemented Revised Code finalized on July 21, 2026; application on the TSE began the same day Reflection in in-house CG report, board operations, policy holdings, and human resources strategy
Follow-up on both codes Financial Services Agency/TSE Inspection of implementation status action program 2025 Status of establishment of revised code and stewardship practices
Market segment/cost of capital/growth market TSE Continuous inspection and operation Update of capital cost requirements, new growth market standards, TOPIX reform Disclosure quality, implementation, listing maintenance, index migration
Statutory disclosure system Financial Services Agency/Financial System Council System design in progress Amendments to annual securities reports, human capital, and sustainability disclosures Pre-general meeting disclosure, English disclosure, additional review of descriptive information
Sustainability disclosure/assurance Financial Services Agency/Financial System Council Some disclosures have been finalized, assurance remains under consideration Legislation of gradual application of SSBJ standards Scope of assurance, start date, person in charge of assurance work and supervision
Acquisition practice Ministry of Economy, Trade and Industry Guideline finalization/practical arrangement 2023 Guidelines, 2026 “Points/Q&A” Connection with market practices, court precedents, and TOB system
company legislation Ministry of Justice/Legislative Council System design in progress Companies Act Subcommittee considers interim draft plan Amendments to laws regarding beneficial owners, shareholder meetings, stock systems, and corporate governance
SSBJ standards development SSBJ Standard maintenance/practical support 2025 standards, 2026 revisions, practical standards Practical commentary, response to ISSB revisions, additional theme standards

1. 2026 Corporate Governance Code Revision—already in implementation stage

The Committee of Experts on Revising the Corporate Governance Code, chaired by Yuri Okina, held discussions starting in October 2025 and announced a revised proposal in April 2026. After public comment, the revised version was finalized on July 21, 2026. The TSE also began applying the revised code on the same day.

Therefore, what IR professionals should read now is not a prediction of the future of the conference, but the next document.

  • 2026 revised code text
  • Changes from before revision
  • Purpose and outline of the revision
  • Responses to public comments
  • Collection of case studies related to strengthening the functions of the board of directors 2026

In addition to reflecting the revised content in the CG report, it is also necessary to review board materials, nomination and compensation committees, verification of cross-shareholdings, human resources strategies, and supervision of growth investments.

2. Follow-up meeting: looking at the “substance” of the system

Since 2015, the Financial Services Agency and the Tokyo Stock Exchange's Stewardship Code and Corporate Governance Code Follow-up Meeting have confirmed the implementation status of both codes and published opinions and action programs.

The latest formal Action Program is the 2025 edition. With the 2026 revised Code finalized, the focus has shifted from adding provisions to whether boards effectively oversee growth investment and resource allocation, and whether investor engagement informs decisions.

When reading meeting materials, look not only at good examples where the company's name is mentioned, but also at items organized as issues. This is where the seeds of next year's TSE data, Financial Services Agency review, and next revision appear.

3. TSE market segments follow-up – changing behavior after listing

The TSE's “Follow-up Meeting on Review of Market Segmentation” will address issues such as continued listing criteria after market reorganization, management with an awareness of cost of capital and stock prices, English disclosure, growth markets, and index reform.

The unique feature of this conference is that it changes the behavior of listed companies without creating laws. Combining requests, public listings, case studies, continued listing criteria, and phased transition. IR personnel should read not only news releases, but also meeting materials and TSE's "future actions."

4. Information Disclosure Working Group of the Financial System Council: Creating the next generation of annual securities reports

The Information Disclosure Working Group is responsible for designing the legal disclosure system. Meetings continued in 2026 to address issues such as annual securities reports, semi-annual reports, disclosure before shareholder meetings, human capital, cross-shareholdings, and information in English.

The materials from this meeting are important because they may ultimately lead to Cabinet Office ordinances and disclosure forms. While the Code discussion sets out the principles, the Information Disclosure Working Group specifies who should write what, when, in what format, and so on.

5. Sustainability Information Disclosure and Assurance Working Group—Next focus is on assurance

Regarding the legal application of the SSBJ standards, the Cabinet Office Ordinance revised in February 2026 fixed the application period for prime companies with an average market capitalization of 3 trillion yen or more and 1 trillion yen or more. Meanwhile, the assurance system continues to be considered.

Issues that need to be confirmed in the future include the scope of the limited assurance, the year of commencement, the treatment of Scope 3, the person in charge of assurance work, quality control, and the supervisory system. Target companies need to prepare evidence and internal controls without waiting for the system to be finalized.

6. Ministry of Economy, Trade and Industry's Study Group on Fair Acquisitions - From Guidelines to Practice

The study group reconvened in 2026 and published Key Points and Q&A on the 2023 Guidelines for Corporate Takeovers in July 2026. These documents clarify practical questions; they do not replace the 2023 Guidelines.

Rather than predicting future meeting schedules, IR and legal personnel should incorporate the 2023 Guidelines and 2026 Q&A into their company's acquisition response procedures. Design the acceptance of unsolicited proposals, special committees, information disclosure, and confirmation of shareholder intentions during normal times.

7. Legislative Council Corporate Law Subcommittee: Reviewing the foundations of corporate law

The Ministry of Justice's Corporate Legislation Subcommittee held its first meeting in April 2025 and has continued deliberations since then. It covers issues related to the basics of corporate law, such as shareholder meetings, stocks, beneficial owners, and corporate governance.

While amending the Companies Act will take longer than the Code or the TSE request, if passed it will have legal effects on all stock companies. Since the process proceeds in the order of interim drafts, public comments, draft outlines, and bills, the IR staff separates their role from the legal department and quickly grasps the issues that will affect dialogue with shareholders and the operation of the general meeting.

8. SSBJ—Following the standards even after they are published

SSBJ published three standards in 2025, followed by amendments and practical implementation standards in 2026. A standard setter’s work continues after publication: reference information, handbooks and implementation standards are added as ISSB standards change, domestic legislation develops and practical or industry-specific questions arise.

Target companies need to follow not only the Financial Services Agency's laws and regulations page, but also the SSBJ's standards page, proceedings summaries, and exposure drafts.

How to read until the system is established

Japan's governance system will generally take shape in the following order.

  1. Challenges are expressed in government policies and action programs.
  2. Issues are sorted out at expert meetings, study groups, and working groups.
  3. Interim reports, reports, draft guidelines, and exposure drafts will be published.
  4. After public comments, the code, guidelines, Cabinet Office ordinance, and TSE rules will be finalized.
  5. Practical expectations become concrete through FAQs, examples, good practices, and review results.

The earliest signal is the meeting materials, but it is the final document that should confirm the company's response. Do not communicate ideas that are still under consideration to the company as “fixed rules.” On the other hand, if you wait for the final decision to start preparing data and human resources, you will not be able to make it in time. It is important to separately manage the certainty of the system and the reversibility of preparation.

IR department monthly confirmation sheet

frequency Page to check purpose
monthly JPX “Follow-up meeting regarding market segments review” Cost of capital, maintenance of listing, English disclosure, growth market updates
At the meeting Financial Services Agency follow-up meeting Code implementation, dialogue, policy holdings, and board issues
At the meeting Financial System Council Information Disclosure WG System reform for annual securities reports and semi-annual reports
At the meeting Sustainability Disclosure/Assurance WG SSBJ application and assurance system
quarter Ministry of Economy, Trade and Industry's Corporate Governance and Acquisition Related Study Group Acquisitions, group governance, board practice
quarter Legislative Council Corporate Legislation Subcommittee General meeting of shareholders, beneficial owners, and revisions to the Companies Act
monthly SSBJ Standards/Exposure Draft Page Standard revisions, practical responses, explanatory materials

Implications that IR personnel should be aware of

  1. Specify whether "under consideration," "finalized," or "already implemented" for each document. Do not confuse future plans with current obligations in internal briefings.
  2. The 2026 revised code is to be implemented, not predicted. Update the CG report and board practices in light of the latest text.
  3. See the legal nature of the deliverables from the conference name. Opinions, guidelines, codes, Cabinet Office ordinances, and TSE regulations have different effects.
  4. Use meeting materials as leading indicators and final documents as implementation standards. Prepare early and avoid over-investing in uncertain matters.
  5. One system ledger for IR, legal affairs, accounting, sustainability, and human resources. This is because the same amendment covers multiple departments' disclosures and board operations.

Source/reference materials

Next to this curriculum: IR Toolbox - Search for primary materials of JPX, Financial Services Agency, Ministry of Economy, Trade and Industry, and SSBJ

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