Defining the Nonprofit Sectors in Japan and England & Wales : A Comparative Assessment of Common Versus Civil Law

This paper provides a comparative assessment of the legal frameworks for non-profit organisations (NPOs) in England and Japan, offering fresh insights into the differences in legislative support for NPO development in both countries. Following a review of NPO legal developments in England and Japan, we outline the major contemporary issues affecting NPOs and focus on the key challenges of: legislative reform, systems of regulation, accountability and third/public sector partnerships. The paper contributes to knowledge by exploring the potential of comparative assessments of NPO legislation, and highlights the disparities in support for NPOs that are culturally-bound. Also, we contribute to contemporary debate on the ability for NPOs to manage amidst a global climate of change and the possible return to the so-called ‘age of austerity’. Highlighting the differential roles of legal frameworks between cultural contexts shows academics, practitioners and policy makers, the global context of national challenges for NPOs