8 minute read | May.19.2026
日本語: 日本再生可能エネルギーアラート 72号
In this alert, we introduce the mandatory JC-STAR ★1 certification requirements, taking into account recent explanations provided by the Agency for Natural Resources and Energy (ANRE) under the Ministry of Economy, Trade and Industry (METI). We also cover other topics that have recently attracted numerous inquiries.
As the importance of cybersecurity measures for distributed energy resources (DERs) such as renewable energy sources and grid-connected storage batteries continues to grow, from April 2027 (October 2027 for low-voltage connections), as a cybersecurity measure required under the Interconnection Technical Requirements (a supplement to the Terms and Conditions for Wheeling Services established by TDSOs (transmission and distribution system operators)), obtaining JC-STAR ★1 certification will be mandatory for equipment with IP communication functions (such as PCS, remote surveillance system) of storage batteries and solar power, as well as control systems with communication functions for wind power generation equipment.
JC-STAR (Japan Cyber-Security Technical Assessment Requirements) is a security-level labeling scheme for IoT products operated by the Information-technology Promotion Agency, Japan (IPA). The ★1 level is designated as a “unified minimum conformity standard” for products capable of connecting to the internet. Furthermore, ANRE is considering the future development and introduction of a JC-STAR “★2” standard as a standard specific to distributed energy resources, taking into account the characteristics of such resources.
In this regard, the Japan Sustainable Energy Council (JSEC) held a seminar at the House of Representatives Members’ Office Building on April 24, 2026 where ANRE officials provided explanations on the details of the applicability of the revised requirements.
Orrick has sought clarification on the details of the applicability of the revised requirements through an independent inquiry to ANRE, as well as through advance questions submitted for the above seminar. In the materials of the 21st meeting of the Grid Code Study Group (held in March 2026) and at the JSEC seminar, ANRE explicitly explained that the requirements will apply to interconnection contract applications (formally accepted upon payment of the deposit and submission of required documents) on or after the effective date (for high voltage and special high voltage, April 2027).
On the other hand, with respect to existing projects, ANRE mentions that the new requirement will be applicable to the facility at the time of the replacement of equipment. During the seminar’s Q&A session, ANRE indicated that the revised requirement will be applicable not only at the time of repowering, but also in cases of equipment replacement due to malfunction. ANRE further suggested that, while the details should be consulted with relevant TDSOs, all equipment contained in a power plant may need be updated to those with JC-STAR certification at the time of replacement of one unit among multiple PCS units of the power plant.
The mandatory requirement of JC-STAR ★1 certification is of particularly high importance among recent Grid Code revisions as it may have significant implications for both new and existing projects. Orrick has received multiple inquiries and has been actively engaged in this matter. Please do not hesitate to contact us if you have any concerns or questions.
On April 22, 2026, MOE and METI held the fourth meeting of the “Study Group on Environmental Impact Assessment of Solar Power Generation Projects, etc.” and published a draft report (see here).
The draft report states that, in light of the characteristics of solar power projects—such as the diversity of project locations, large-scale land alteration, impacts from reflected light and on the landscape, and the ease of construction—there is a certain degree of rationality in making projects of a scale smaller than the 100-hectare equivalent, which serves as the basic threshold for Class 1 projects, subject to the Act (p. 5). However, the specific Class 1 scale requirement after the reduction has not been specified at the draft report stage.
With respect to wind power projects, given that relatively little time has passed since the last revision of the scale requirements and it is anticipated that wind power plants to be constructed going forward will primarily be those with an output of 50,000 kW or more, no revision of the Class 1 scale requirement was considered necessary. On the other hand, the direction for revision of the Class 2 scale will be set out following further discussion at the study group (p. 12).
In addition, revisions to screening criteria common to both solar and wind power projects are being considered. Specifically, the draft report describes the potential addition of screening criteria where regulated areas under forestry-related laws and regulations exist, as well as the consideration of new screening criteria relating to land alteration on sloped terrain and similar areas (pp. 8, 12).
As matters common to the institutional reforms, the importance of ensuring predictability through appropriate application of transitional measures, and of raising awareness of the concept of project continuity, has also been confirmed. Going forward, it is expected that conclusions on specific amendments will be presented in the first half of 2026, followed by corresponding amendments to the Enforcement Order for the Environmental Impact Assessment Act.
Regarding grid connections for BESS, given that the interconnection process has been delayed due to low-feasibility interconnection study applications, the direction of setting an upper limit on the number of interconnection studies per operator had been indicated at METI’s advisory council.
At the 10th meeting of the Next-Generation Power Grid Working Group (the “Grid Working Group”) held on April 16, 2026 (see here), it was reported that the relevant rules and regulations of OCCTO are scheduled to be amended as of August 1, 2026, with the upper limit measure taking effect on the same date.
As a transitional measure, projects that have already been accepted as of July 31 will be processed as before, while projects for which applications were submitted before August 1 but have not yet been accepted as of August 1 will be subject to the upper limit. For applications that have not been accepted and exceed the upper limit, the TDSO will notify the relevant operators. The specific upper limit numbers are currently being calculated by each TDSO and are expected to be published on each company’s website upon completion. For reference, based on trial calculations as of March 2026, the figures are 11 for the Tokyo area, 10 for the Kansai area, 8 each for the Hokuriku and Kyushu areas, 6 for the Tohoku area, and 5 each for the Hokkaido, Chubu, Chugoku, and Shikoku areas; however, it should be noted that the actual upper limit numbers may differ from these figures.
Grid connection procedures have been subject to increasing stringency, including the introduction of a requirement for non-FIT and non-FIP power sources to submit documents evidencing land rights, as well as an increase in the grid connection deposit for BESS projects from 5% to 10% of the estimated construction cost charges payable to a relevant TDSO in relation to the interconnection construction. As grid connection applications for BESS projects are expected to continue, it is necessary to pay attention to these regulatory developments.
In April 2026, Orrick published its global energy storage report, “Energy Storage Update 2026: Data Centers, Revenue Opportunities, OBBBA and Tariffs.” The report was authored by a cross-disciplinary team of over 40 experts across 10 offices, comprehensively covering BESS applications for data centers, new revenue opportunities, OBBBA and FEOC, tariffs, Battery Trade Agreements, permitting, and fire risk. The report covers Japan, the United States, the EU, Germany, France, the United Kingdom, Singapore, the Philippines, Vietnam, Indonesia, Malaysia, Thailand, and India. This guide will be of interest to energy storage developers, sponsors and investors, utilities, data center operators, equipment manufacturers, offtakers, and financing parties.
Our Tokyo office’s energy team, composed of attorneys with diverse backgrounds who cooperatively work with our teams overseas, supports clients taking on new challenges in the renewable energy and storage sectors. We are also considering holding events beneficial to developers and investors in the future.