Japan's smartphone law requires Apple and Google to allow rival app stores and payments

Japan's Mobile Software Competition Act, often called the MSCA, sets rules for the companies that run the main smartphone software platforms in Japan. Its formal name is the Act on Promotion of Competition for Specified Smartphone Software. The Diet passed it on 12 June 2024. The Act reached full effect in December 2025, and it covers app stores, payments inside apps, browsers, search and the choice of default apps.

For app developers, the rules change how apps can reach iPhone and Android users in Japan and how they can take payment. The Japan Fair Trade Commission (JFTC) enforces the law. The European Union's Digital Markets Act is one point of comparison, and its penalty structure is different.

Which companies and services are covered

The Act covers four kinds of Specified Software: mobile operating systems, application stores, browsers and search engines. The JFTC designates providers of this software, and they are called Designated Providers.

A Wolters Kluwer Competition Law Blog post dates the Cabinet Order and Enforcement Rules to December 2024. The same post says the JFTC designated the three companies below in March 2025.

In March 2025 the JFTC designated Apple Inc. for its operating system, app store and browser. It designated iTunes K.K., which jointly operates the App Store in Japan. It designated Google LLC for its operating system, app store, browser and search engine.

Articles 5 to 9 set out prohibited conduct, and Articles 10 to 13 set out compliance requirements. Not every article applies to every service. Article 9, which covers search self-preferencing, applies only to search engines.

Alternative app stores and app review

Article 6 bars unjust discrimination or other unfair treatment of app providers during app review, including review for alternative app stores.

Article 7 bars hindering alternative app stores. That covers limiting distribution to a company's own store, and preventing alternatives from operating. PPC Land reports that this covers direct refusals to license an app store and indirect actions that make distribution difficult.

Under Article 7, a violation does not require that an alternative store be made impossible to operate. According to PPC Land, a high likelihood of making it difficult for businesses to provide app stores and for users to employ them is enough.

Article 7 also bars hindering other businesses from using operating system functions that have equivalent performance. According to the Wolters Kluwer post, the guidelines require comparable functionality for third parties, not identical technical access.

Alternative payments

Article 8 bars restricting alternative payment management services. This includes conditioning app store access or otherwise hindering that use.

Google responded on the day the Act took effect. It extended its User Choice Billing program, which had covered non-gaming apps since 2022, to all apps that sell digital content through in-app purchases to Japanese users. It also created a program that lets developers offer a choice between Google Play Billing and purchases completed on their own websites. PPC Land reports that this option carries competitive fee offerings and security and user-safety requirements, and that developers can begin onboarding immediately, with APIs becoming available shortly.

Apple made parallel changes in iOS 26.2 on December 17. The update allows alternative app marketplaces and alternative payment options in Japan, with guardrails for the Kids category and for users under 18. PPC Land also reports that apps using alternative payments or website links must include parental gates for users under 18. Apps for users under 13 cannot link to websites for transactions, and Kids category apps will not include website transaction links.

Browsers, search and default choice screens

Article 8 also bars banning alternative browser engines, including making app store access conditional on such a ban.

Article 12 requires providers of operating systems and browsers to ensure that default settings for those services can be changed through simple operations. The guidelines include a browser choice screen.

Google's compliance measures include choice screens that prompt users to pick a search engine and a browser. These appear on Android phones and in the Chrome app on iOS in Japan. PPC Land reports that Google announced these measures on 17 December 2025.

How the JFTC enforces the Act and what it can impose

The JFTC published draft subordinate rules and guidelines for public comment from 15 May to 13 June 2025. It received 105 comments. The final Cabinet Order, JFTC Rules and Guidelines were published on 29 July 2025.

The Act sets a surcharge payment order equal to 20% of relevant turnover. The JFTC can also investigate and issue cease-and-desist orders. Designated providers must submit compliance reports.

Some conduct can be justified only on grounds listed in the guidelines. According to the Wolters Kluwer post, there are five: cybersecurity, protection of user information, safeguarding minors, physical safety of smartphone hardware, and prevention of criminal activity. The designated provider must also conduct necessity and proportionality tests. The guidelines do not accept systematic warnings that alternative app stores are unsafe as a justification.

The JFTC's July 2025 release gives 18 December 2025 as the date of full effect. A Wolters Kluwer post also gives 18 December 2025. PPC Land reports that the Act took effect on 17 December 2025, citing Google's announcement. The enactment release says the Act takes effect on a date set by Cabinet Order, within one and a half years after the bill was promulgated.

How the EU Digital Markets Act compares

Under Article 30 of the DMA, the European Commission can fine a gatekeeper up to 10% of its total worldwide turnover in the preceding financial year. The ceiling applies to intentional or negligent breaches of Articles 5, 6 and 7 and of certain other decisions and commitments. Those other decisions include failure to comply with interim measures and with commitments made legally binding.

The DMA raises the ceiling to 20% of total worldwide turnover for a repeat of the same or a similar infringement. The earlier finding must concern the same core platform service and come from a non-compliance decision within the preceding eight years.

Procedural failures, such as supplying incorrect information, can draw fines of up to 1% of worldwide turnover. The Commission considers gravity, duration and recurrence when it sets the amount. For procedural fines, it also considers any delay caused to the proceedings.

The two regimes use different bases. The DMA ceiling is a percentage of total worldwide turnover, while the Japanese surcharge is a percentage of relevant turnover. The JFTC's enactment release gives a 20% rate. The rules apply to the companies the regulator has named, and they reach users in Japan.