Japanese universities are strongly encouraged to formulate policies on research data and many have published research data polices in the last five years. When designing their research data services, universities must bear their institution’s research policy and the standard policy in Japan in mind. This study aimed to clarify the overall trends and characteristics of the research data policies developed by Japanese universities. This study presents a preliminary analysis of 70 research data policies that Japanese universities have formulated and published from March 2020 to June 2024. Policy titles, elements of structure, policy subjects, responsibility for data management, and terms used for researchers’ responsibilities and rights were examined. It transpired that while the elements described were generally common, there were differences in the policy titles and terminology used. Most of the policies incorporated the management and sharing of data, but did not address the early stages of the research process, such as data management planning.