There is a strong trend of adopting “complementary protection” as part of refugee protection policies in the world. Japan also grants so-called “status of humanitarian consideration” to those who fall outside the refugee defi nition under the Refugee Convention. In this paper, however, the author will argue that there is still much room for improvement in the complementary protection in Japan. By introducing international discussion on the “protection gap” and the impact of the 2011 revision of the European Union Qualification Directive, it will conclude that Japan must adopt a more advanced complementary protection policy to comply with the principle of non-discrimination.