Standards Comparison

    APPI

    Mandatory
    2003

    Japan's national law regulating personal data protection

    VS

    ISO 27018

    Voluntary
    2019

    Code of practice for PII protection in public clouds

    Quick Verdict

    APPI mandates personal data protection for Japan operations, while ISO 27018 provides voluntary cloud PII controls. Companies adopt APPI for legal compliance in Japan; ISO 27018 for global cloud trust and procurement acceleration.

    Data Privacy

    APPI

    Act on the Protection of Personal Information

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Extraterritorial scope for firms targeting Japanese residents
    • Pseudonymized data allows consent-free purpose changes
    • Explicit prior consent for sensitive data transfers
    • PPC enforces with up to ¥100M administrative fines
    • Data subject rights fulfilled within 30 days
    Cloud Privacy

    ISO 27018

    ISO/IEC 27018:2025 Code of practice for PII protection

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • Privacy controls for public cloud PII processors
    • Subprocessor transparency and location disclosures
    • Breach notification obligations to customers
    • Prohibits PII use for marketing without consent
    • Supports data subject rights and deletion

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    APPI Details

    What It Is

    The Act on the Protection of Personal Information (APPI), enacted in 2003 and amended through 2024, is Japan's cornerstone national regulation for personal data handling. It defines personal information broadly, including pseudonymous data, and applies extraterritorially to businesses targeting Japanese residents. Primary purpose: balance privacy rights with data utility via risk-based principles like purpose limitation, consent, and security.

    Key Components

    • Pillars: transparency, minimization, data subject rights (access, correction, deletion in 30 days), security controls.
    • Sensitive data (medical, race) and cross-border transfers require explicit consent.
    • Pseudonymously Processed Information enables analytics flexibility.
    • Enforced by independent PPC with ¥100M fines, audits, breach notifications. No formal certification; compliance through self-assessments and guidelines.

    Why Organizations Use It

    Mandatory for data handlers; non-compliance risks fines, reputational harm, market blocks. Drives trust (78% consumers prefer compliant brands), efficiency (15-25% cost savings), cross-border adequacy (EU mutual). Strategic moat for tech, e-commerce, finance in Japan's economy.

    Implementation Overview

    5-phase framework (12-24 months): gap analysis, governance, technical controls (encryption, RBAC), testing, monitoring. Applies to all sizes/industries handling Japanese data; SMEs lighter touch, enterprises need DPOs, PPC scrutiny.

    ISO 27018 Details

    What It Is

    ISO/IEC 27018 is an international code of practice extending ISO/IEC 27001 and ISO/IEC 27002 specifically for protecting personally identifiable information (PII) processed by public cloud service providers acting as PII processors. First published in 2014, revised in 2019 and 2025, it uses a risk-based approach within an Information Security Management System (ISMS) to address cloud privacy challenges like multi-tenancy and cross-border data flows.

    Key Components

    • ~25–30 additional privacy-specific controls on consent, purpose limitation, data minimization, transparency, and accountability
    • Mapped to ISO 27001 Annex A organizational, people, physical, and technological themes
    • Core principles: consent/choice, accuracy, security safeguards, limited retention/disclosure
    • Assessed via ISO 27001 audits; no standalone certification

    Why Organizations Use It

    • Demonstrates processor compliance with GDPR Article 28, HIPAA
    • Builds customer trust, accelerates procurement, reduces questionnaire friction
    • Manages cloud PII risks, supports cyber insurance
    • Competitive edge for CSPs via audited transparency

    Implementation Overview

    • Conduct gap analysis on existing ISMS; update Statement of Applicability
    • Develop policies for subprocessors, breaches, data rights support
    • Applicable to CSPs all sizes/industries; third-party audits required
    • Incremental effort low if ISO 27001-certified (176 words)

    Key Differences

    Scope

    APPI
    Personal data handling in Japan
    ISO 27018
    PII protection in public clouds

    Industry

    APPI
    All sectors targeting Japan
    ISO 27018
    Cloud service providers globally

    Nature

    APPI
    Mandatory Japanese law
    ISO 27018
    Voluntary ISO code of practice

    Testing

    APPI
    PPC audits and inspections
    ISO 27018
    ISO 27001 integrated audits

    Penalties

    APPI
    ¥100M fines, imprisonment
    ISO 27018
    Loss of certification

    Frequently Asked Questions

    Common questions about APPI and ISO 27018

    APPI FAQ

    ISO 27018 FAQ

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