The JPO has been permitting recordation of non-exclusive licenses that result from a comprehensive license agreement since October 1, 2008.

A comprehensive license agreement submitted to the JPO must meet the following requirements:

1. the licensee is granted a non-exclusive license for patents and/or utility models, or a non-exclusive license from an exclusive license for patents or utility models,
2. entered into between organizations,
3. prepared in writing, and
4. patent or utility model numbers are not indicated in the agreement.