The National Diet Library (NDL) says that games released on Nintendo Switch 2 game-key cards will not be eligible for preservation (source: Famitsu). The NDL is one of the largest libraries in the world, and it’s also Japan’s only legal deposit library, meaning that it mandates domestic publishers to submit copies of all new publications for collection and preservation purposes.
As of October 2000, the library started housing media such as video game CDs and cartridges in proper archival conditions, becoming the key institution for preservation of Japanese games. Currently, NDL possesses over 9,600 video game titles, including most titles published domestically since October 2000 (only physical releases), and some titles published prior (collected via donations).
When asked about Switch 2 game-key cards, NDL representatives say that “only physical media that contains the content itself” is considered eligible for preservation. “Since a key card, on its own, does not qualify as content, it falls outside of our scope for collection and preservation.”

As key cards merely serve as a “key” for downloading a game to your console via the internet, the library is essentially treating them the same as digital-only releases. At the same time, contrary to regular digital releases, games stored on key cards require you to insert the key card into your Switch 2 each time you play (as per Nintendo), meaning that the “physical” aspect to them is not zero either, despite game data not actually being stored on them.
Japan’s NDL has recently begun archiving digital books and magazines (which had not been a thing previously), which could mean the rules could change for video games too somewhere down the line. But for now, new games releasing on Switch 2’s cheaper alternative to physical carts will be left out from preservation efforts much like download-only games.
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The perfect way to not preserve games ಠ ل͟ ಠ