The proliferation of autonomous AI agents is creating governance challenges that existing digital identity and authorization frameworks were not designed to address. The EU’s eIDAS 2 (Regulation 2024/1183), NIST CAISI’s AI Agent Standards Initiative, and the FIDO Alliance’s Agent Payments Protocol (AP2) each provide partial frameworks, but all of them embed institutional assumptions that cannot be transplanted directly into Japan’s legal context. This paper conducts a structured conceptual mapping of ten core governance requirements against Japan’s existing institutional foundations: the Electronic Signatures Act (2000), the Electronic Power of Attorney Act (2017), and the Digital Agency’s Trusted Web initiative. The ten requirements were organized by combining governance functions stated or implied in the three international frameworks with the author’s normative additions where all three share a structural gap (most notably agent-specific revocation). The analysis identifies five structural gaps: (G1) the absence of an agent-specific identity regime, (G2) legally underdeveloped delegation chains, (G3) fragmented cross-ministry attribute attestation, (G4) the absence of runtime governance mechanisms, and (G5) an unresolved liability attribution framework. The 2024 EU–Japan Memorandum of Cooperation on Digital Identities and Trust Services provides a relevant policy context for exploratory interoperability work, but does not itself establish mutual recognition or AI-agent delegation rules. Building on Japan’s existing institutional building blocks, the paper proposes a five-layer delegation architecture and an illustrative three-phase implementation roadmap (2026–2028 and beyond). The proposal is presented as a policy-design hypothesis for further legal, technical, and stakeholder validation, rather than as evidence that an internationally interoperable framework can already be achieved through limited legislative reform. Illustrative sector-specific implementation checklists for financial services, healthcare, and public administration are also provided to support policy discussion.
Kenichi Kajitani (Wed,) studied this question.