In 2025 and 2026, two bribery cases involving physicians affiliated with the University of Tokyo highlighted corruption risks in Japan’s healthcare sector.
On 19 November 2025, a University of Tokyo Hospital physician was arrested on suspicion of accepting bribes from a medical device manufacturer listed on the Tokyo Stock Exchange. Reports said the company made an “academic donation” (shōgaku kifu) of JPY800,000 (USD5,152) to the hospital. Of that amount, JPY700,000 was allegedly transferred to the physician personally in exchange for preferential use of the company’s medical devices in surgical procedures. The physician allegedly used the funds for personal purposes. While academic donations are common and lawful in Japan, they may constitute criminal bribery if linked to specific purchasing or usage decisions.
On 24 January 2026, another University of Tokyo physician was arrested for allegedly receiving repeated lavish entertainment and hospitality – reportedly including sexual services – from a director of an NGO known as the Japan Cosmetics Association. The physician was a Department of Dermatology professor and was conducting clinical cannabinoid research. The allegations surfaced after a business dispute between the professor and the NGO. The NGO director publicly disclosed the provision of excessive entertainment and filed a civil lawsuit against both the professor and the university.
Japan’s bribery law framework and enforcement
Representative Partner
GI&T Law Office
Tokyo
Japan is widely regarded as one of the least corrupt countries in the world. Nevertheless, the healthcare industry – particularly the medical device sector – remains an area of recurring enforcement activity.
Domestic bribery. Under the Japanese Penal Code, bribery of public officials is a criminal offence. Physicians employed by public hospitals, including national university hospitals, are treated as public officials or deemed equivalent for the purposes of the anti-bribery provisions. Providing benefits to such physicians in exchange for favourable treatment may constitute criminal bribery.
Private-sector bribery is generally not criminalised, except where it constitutes fraud or breach of trust.
Foreign bribery. Bribery of foreign public officials is prohibited under article 18 of the Unfair Competition Prevention Act. However, enforcement is limited. Since the foreign bribery provision took effect in 1999, only 10 cases have been prosecuted.
Industry self-regulation. In addition to criminal statutes, industry self-regulation plays a key role. The Japan Fair Trade Council of the Medical Devices Industry has set up a Fair Competition Code (FCC) under the Act against Unjustifiable Premiums and Misleading Representations. The FCC sets standards governing interactions with healthcare professionals including meals, gifts, hospitality, services and speaker engagements. While violations do not automatically result in criminal liability, they may trigger administrative action and reputational damage.
Compliance challenges, internal investigations in Japan’s healthcare sector
Counsel
GI&T Law Office
Tokyo
Internal investigations in the medical device sector reveal recurring compliance weaknesses. Many companies maintain compliance systems requiring documentation for donations and sponsorships. On paper, the procedures appear robust. But, in practice, approvals are mechanical and little substantive review is done on the legitimacy of the transactions.
Two common risk patterns frequently emerge.
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- Academic donations (shōgaku kifu) to public university hospitals are formally recorded as legitimate contributions but may, in substance, be connected to product selection decisions; and
- Healthcare professionals are repeatedly invited to speak at company-sponsored events, creating opportunities to provide substantial speaker fees under the appearance of educational programming. Excessive frequency or disproportionate compensation may raise bribery concerns.
Strengthening substantive compliance in Japan’s healthcare industry
Counsel
GI&T Law Office
Tokyo
To mitigate bribery risks, companies must adopt systems to evaluate substantive legitimacy. Effective measures may include:
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- establishing objective standards on the amount and frequency of academic donations;
- defining criteria to assess the scientific and social value of sponsored events;
- monitoring repeat engagements involving the same healthcare professionals; and
- ensuring an independent compliance review rather than automatic approval.
Given physicians’ discretion and market competition, industry interactions require careful oversight.
Conclusion
Recent cases involving prominent academic institutions show that even commonly accepted practices, such as academic donations and speaker programmes, may give rise to criminal liability when improperly structured. For companies operating in Japan’s healthcare market, effective compliance requires more than procedural formality. It demands substantive evaluation, clear standards and organisational commitment.
Kengo Nishigaki is a representative partner, and Andrew Marriott and Nobuhiro Matsuo are counsel at GI&T Law Office in Tokyo
GI&T Law Office23F Marunouchi Kitaguchi Building,
1-6-5 Marunouchi, Chiyoda-ku,
Tokyo 100-0005, Japan
www.giandt-law.com
Tel: +81 3 6206 3283
Email: kengo.nishigaki@giandt-law.com
