Cybersecurity requirements for grid interconnections of power generation facilities are being strengthened. Under amendments to the Interconnection Technical Requirements established by general transmission and distribution operators (TDSOs), equipment with IP communication functions used in solar power, battery storage, wind power, and other facilities (including PCS, BMS, and EMS output control devices, remote monitoring devices, and gateways) must have obtained the JC-STAR ★1 conformance label under the Security Labeling Scheme operated by the Information-technology Promotion Agency, Japan (IPA) in order to connect to the grid. For high-voltage and extra-high-voltage solar power and battery storage facilities, the revised requirements will apply to projects for which the relevant TDSO accepts a contract application on or after April 1, 2027.
Existing equipment that has not obtained JC-STAR ★1 certification will not need to be replaced immediately when the new requirements take effect in April 2027. However, particular care is needed when covered equipment at an existing facility is replaced due to a malfunction or for other reasons. It had previously been suggested that, when replacing some equipment at an existing facility, all equipment at the power generation facility, including equipment not being replaced, could be required to comply with the new requirements. In July 2026, the Agency for Natural Resources and Energy (ANRE) updated its Q&A on JC-STAR ★1 and set out its policy on the treatment of equipment replacement at existing facilities.
According to Q&A No. 11, the use of JC-STAR ★1-certified products is required, in principle, even when only some existing equipment is replaced due to malfunction or for other reasons. However, where replacement with JC-STAR ★1-certified products would impose an “excessive burden” on the operator, an exception permits replacement with a product of the same type that has not obtained JC-STAR ★1 certification, subject to certain procedures.
Examples of an “excessive burden” include burdens where:
If an operator seeks to replace equipment with a product of the same type that has not obtained JC-STAR ★1 certification on the basis of an excessive burden, the operator must consult with the relevant TDSO and submit a plan describing: (i) why replacement with a JC-STAR ★1-certified product is difficult; (ii) the specific timing for a broad replacement or repowering of the facility and for replacing all covered equipment with JC-STAR ★1-certified products; and (iii) the cybersecurity measures to be implemented until that replacement is completed.
This exception allows products that have not obtained JC-STAR ★1 certification to be used only “for the time being.” In the longer term, covered equipment will need to be replaced with JC-STAR ★1-certified products.
The list of products that have obtained JC-STAR conformance labels published by IPA, last updated on August 18, 2026, does not currently include any JC-STAR ★1-certified products from major Chinese manufacturers. If this remains the case after April 2027, operators of existing projects may be unable to replace a failed PCS or other equipment with a certified product from the same manufacturer and may need to switch to equipment from another manufacturer.
For new projects, the April 2027 effective date is fast approaching. The new requirements will also affect future equipment replacement at existing projects. For both projects under development and operating projects, it is therefore important to confirm at an early stage whether the relevant equipment has obtained JC-STAR ★1 certification and whether alternatives are available. Operators currently using products that have not obtained certification, as well as operators seeking to acquire projects that use such products, should confirm when those products are expected to obtain JC-STAR ★1 certification and identify alternative equipment in case certification is not obtained. Operators considering reliance on the exception are also advised to assess whether they are likely to satisfy its requirements.