--- title: "Public Records Management Act: Files, Archives, and Use" description: "Explains how the Public Records and Archives Management Act governs document creation, file registers, transfer, use, review, and oversight." date: 2026-05-27 category: Law Commentary tags: [Public Records, Administration] draft: false --- The [Public Records and Archives Management Act](https://elaws.jp/view/421AC0000000066) sets rules for managing public records and archives held by national Administrative Organs and Incorporated Administrative Agencies, etc. Article 1 identifies two connected functions: proper management of Administrative Documents, etc., and appropriate preservation and use of Historical Public Records and Archives. A reader checking whether a government record must be created, filed, preserved, transferred, used, or reviewed can trace the relevant step through the Act's chapters. This article explains the Act's record lifecycle rules and the role of the Public Records and Archives Management Commission, but it does not cover agency-specific record schedules or individual archive-use decisions. ## Public Records as Administrative and Historical Records The Act defines several record categories before it assigns management duties. Article 2 is the key provision for identifying whether a record is an Administrative Document, a Corporate Document, a Historical Public Record and Archive, or a Specified Historical Public Record and Archive. Article 2(1) defines Administrative Organs by listing national bodies, including organs established in the Cabinet by law, the Cabinet Office, the Imperial Household Agency, organs under the Cabinet Office Establishment Act and National Government Organization Act, specified facilities and special organs designated by Cabinet Order, and the Board of Audit. Article 2(4) defines an Administrative Document as a document, drawing, or electronic or magnetic record made or obtained by an officer of an Administrative Organ in the course of duties, organizationally used by officers of that organ, and held by that organ. The same paragraph excludes publications issued for sale to an unspecified large number of persons, Specified Historical Public Records and Archives, and materials specially managed as historical, cultural, or academic research materials in facilities designated by Cabinet Order. Article 2(5) defines a Corporate Document for Incorporated Administrative Agencies, etc. using a structure parallel to the Administrative Document definition. Article 2(6) defines Historical Public Records and Archives as records of important historical materials, and Article 2(7) defines Specified Historical Public Records and Archives by listing materials transferred to the National Archives of Japan, etc., materials transferred from national organs other than Administrative Organs, and materials donated or deposited by corporations or individuals. Article 3 states the general principle that public records and archives must be properly managed. ## Creation, Organization, and Transfer of Administrative Documents The Administrative Document chapter follows the record from creation to preservation, file registration, transfer, or disposal. Article 4 begins the lifecycle by requiring an officer of an Administrative Organ to create documents when a decision-making process or the status of affairs and projects must be rationally traced or verified, unless processing concerns a minor matter. Article 5 then addresses organization. The head of an Administrative Organ must organize Administrative Documents according to a classification and naming system that permits mutual relationships and efficient search, and must set a retention period and expiration date for retention before the period expires. Article 5(5) requires extension of a retention period where necessary, and Article 5(6) states that the head of the Administrative Organ must not dispose of an Administrative Document until the retention period has expired. Article 6 requires preservation of Administrative Documents in a place and recording medium needed for proper preservation and use, according to content, passage of time, usage, recording medium, and preservation status. Article 7 requires the head of an Administrative Organ to enter matters such as classification, name, retention period, expiration date, post-expiration disposition, and storage location in an Administrative Document File Register, except for files with retention periods shorter than the period prescribed by Cabinet Order. Article 7(2) requires the register to be kept at the office and published by an electronic data processing system or other information and communications technology. Article 8 assigns the post-retention decision: files that fall under Historical Public Records and Archives are transferred to the National Archives of Japan, etc., and other files are disposed of, with Prime Minister consent required for disposal under Article 8(2). ## Corporate Documents of Incorporated Administrative Agencies Chapter III addresses Corporate Documents held by Incorporated Administrative Agencies, etc. Article 11 sets the management rule for Corporate Documents by requiring Incorporated Administrative Agencies, etc. to manage them properly in accordance with Articles 4 through 6. Article 11(2) requires an Incorporated Administrative Agency, etc. to enter matters concerning Corporate Document Files, etc. in a Corporate Document File Register. The listed matters include classification, name, retention period, expiration date, post-expiration disposition, storage location, and other matters necessary for proper management, excluding information falling within Non-Disclosure Information under the Act on Access to Information Held by Incorporated Administrative Agencies, etc. Article 11(3) requires the register to be kept at the office and published electronically or by another information and communications technology method. Article 11(4) requires transfer to the National Archives of Japan, etc. when a Corporate Document File, etc. whose retention period has expired falls under Historical Public Records and Archives, and disposal for other files. Article 11(5) requires an opinion to be attached when a transferred Corporate Document File, etc. is considered appropriate for use restrictions under Article 16(1), item (ii). Article 12 requires annual reports to the Prime Minister on the status of Corporate Document management and requires the Prime Minister to compile and publish the summaries. Article 13 requires each Incorporated Administrative Agency, etc. to establish and publish Corporate Document Management Rules. ## Access to Specified Historical Public Records and Archives Chapter IV changes the subject from active administrative management to preservation and use of Historical Public Records and Archives. Article 15 requires the head of the National Archives of Japan, etc. to permanently preserve Specified Historical Public Records and Archives unless they are disposed of under Article 25. Article 15(2) requires preservation in a necessary place and by an appropriate recording medium, with measures for easy identification, according to content, preservation status, passage of time, and usage. Article 15(3) requires necessary measures to prevent leakage where personal information is recorded. Article 15(4) requires a catalog containing classification, title, name of the transferring, donating, or depositing person or body, timing of transfer, donation, or deposit, storage location, and other matters necessary for proper preservation and use, and requires that catalog to be published. Article 16 sets the rule for Use Requests. When a Use Request is made according to the catalog for Specified Historical Public Records and Archives preserved by the National Archives of Japan, etc., the head of the National Archives of Japan, etc. must make them available for use except in the cases listed in Article 16(1). Those cases include specified information categories tied to the information disclosure statutes, restrictions agreed with a national organ other than an Administrative Organ, unexpired nondisclosure conditions attached to donation or deposit, and cases where use of the original would risk damage or staining or where the original is currently being used. Article 17 creates a special rule for a Use Request made by the data subject identified by information recorded in Specified Historical Public Records and Archives. If documents proving identity are presented or submitted as prescribed by Cabinet Order, Article 17 requires use of the relevant personal-information portions despite Article 16(1), items (i)(a) and (ii)(a), except where information that may harm the person's life, health, livelihood, or property is recorded. Article 18 provides third-party opinion procedures, Article 19 sets use methods, and Article 20 provides fees for copies. Article 21 provides the review route for a person dissatisfied with a disposition on a Use Request or inaction concerning a Use Request. It allows a Request for Administrative Review to be made to the head of the National Archives of Japan, etc.; modifies the application of the Administrative Complaint Review Act; and requires consultation with the Public Records and Archives Management Commission unless the request is dismissed as unlawful or fully accepted without an opposing opinion. Article 22 applies review-related provisions from the incorporated-administrative-agency information disclosure statute and the Information Disclosure and Personal Information Protection Review Board Act with replacements. ## Promotion, Disposal, Commission Review, and Local Measures The Act also includes provisions that are not limited to one requested archive item. These provisions concern wider access, disposal of records after archival preservation, reports on preservation and use, operating rules, the Public Records and Archives Management Commission, investigation powers, training, technical advice, and Local Government measures. Article 23 requires the head of the National Archives of Japan, etc. to make efforts to make usable Specified Historical Public Records and Archives available for general use by exhibitions and other methods. Article 24 provides a special rule under which Article 16(1), items (i) and (ii) do not apply when the Administrative Organ or Incorporated Administrative Agency, etc. that transferred a Specified Historical Public Record and Archive makes a Use Request because the record is necessary for its affairs or business. Article 25 allows disposal of a preserved Specified Historical Public Record and Archive when it is no longer considered important as historical material, after consultation with and consent from the Prime Minister. Article 26 requires annual reports to the Prime Minister on preservation and use, and Article 27 requires rules on preservation, use, and disposal. Article 28 establishes the Public Records and Archives Management Commission in the Cabinet Office. Article 29 requires the Prime Minister to consult the Commission when planning specified Cabinet Orders, when giving specified consent, and when making recommendations under Article 31. Article 30 allows the Commission to request materials or opinions from the Prime Minister or the head of the National Archives of Japan, etc. Article 31 allows the Prime Minister to request reports or materials, conduct on-site investigations, and make recommendations to the head of an Administrative Organ when necessary for proper management of Administrative Documents. Article 32 requires necessary training, Article 33 allows technical advice or assistance by the National Archives of Japan, and Article 34 requires Local Governments to make efforts to take necessary measures for proper management of documents they hold.