Side by Side: How Hard Is It to Change a Constitution?

In Suva this week, the prime minister is defending Fiji’s Constitution (Amendment) Bill 2026, and SODELPA is contesting its 30-day window for submissions. The last attempt, in March 2025, won 40 votes to 14 and still failed, one short of the three-quarters it needed. So the question for the clerk at the gate: what does a constitution demand before it changes, and how often has anyone paid it?

United States

Two-thirds of both houses of Congress, then three-quarters of the states. More than 11,000 amendments have been proposed in Congress since 1787 and 27 ratified, the National Archives says. The most recent took “more than 202 years” and was certified in 1992. A success rate of about a quarter of one percent, with a waiting list measured in centuries.

Japan

Two-thirds of each house of the Diet, then a simple majority in a referendum. Since it took effect in 1947 the constitution “has never been amended,” which Nippon.com reckons makes it the oldest unamended one in the world. The Public Office Election Act, meanwhile, has been revised 54 times since 1950. In April the prime minister called for a revision “a year from now.” Japan keeps its constitution under glass and does the gardening in the statute book.

India

Some 106 amendments to date, The Week counted on Constitution Day in 2024, 76 of them under Congress governments. That is about one every eight months since 1950. India’s constitution is less a monument than a ledger, and the ledger is open on the desk.

South Korea

Two-thirds of the National Assembly, then a referendum that needs both a majority turnout and a majority yes. This spring 187 lawmakers proposed adding the 1980 Gwangju uprising to the preamble and voiding any martial law the Assembly has not approved within 48 hours. The opposition boycotted, leaving no quorum, and the speaker declined to hold the vote, saying “further proceedings would be meaningless.” It would have been the first amendment vote in 39 years. It was lost to an empty room.

Australia

A national majority and a majority of voters in at least four of the six states. Since Federation, 45 proposals have been put to electors, the Australian Electoral Commission says, and 8 carried. The only country here where the public holds the pen, and it has used it mostly to cross things out.

Verdict

Washington’s latest amendment took two centuries, Tokyo has needed none, New Delhi manages one about every eight months, Seoul could not find a quorum and Canberra’s voters have said no 37 times in 45. Fiji, needing three-quarters, missed by one vote and has come back with a fresh bill. Every country on this page believes a constitution should be hard to change. Japan is the only one that took it as an instruction.