External Payments in Japan: The Fine Print Behind Apple and Google’s Compliance

TL;DR

Japan requires Google and Apple to allow external payments, but both platforms implemented tightly controlled programs that preserve commissions, attribution windows, and contractual leverage. While payment links are now possible in Japan, they do not provide true economic independence. The only model that fully avoids platform commissions and policy dependency is an independent web store.

Apple in Japan: Alternative Payment Options and Out-of-App Offers

Key Takeaway for Publishers

Apple implemented Japan’s competition law via a tightly controlled alternative payments framework, formalized in App Store policies, StoreKit entitlements, and contractual terms.

The Fine Print
 

Fees and Attribution

Out-of-app offers are subject to a store services commission on sales completed within 7 days of the link tap.

• 15% default commission on out-of-app offers.
• 10% for App Store Small Business Program, Mini Apps Partner Program, and Video Partner Program participants.
• 10% for auto-renewable subscriptions after their first year.

Transactions within seven days of an external link tap are commissionable, and subscription renewals remain subject to commission. Apple In-App Purchase transactions also incur a separate 5% Apple payment processing fee.
 

Mandatory Side-by-Side Presentation

Unlike the U.S., Apple in Japan requires a strict side-by-side model. When offering in-app alternative payments or links to external purchase websites, developers must simultaneously present Apple In-App Purchase.

Apple mandates:

• IAP appears on every screen where digital goods are merchandised.
• IAP is displayed at least as prominently as any alternative option.
• Payment flows must not discourage IAP use.
• App Store product pages cannot reference external purchasing options.

This applies to both in-app and out-of-app alternative flows.
 

UX, Disclosures, and Entitlements

Developers must:

• Accept updated Apple Developer Program License Agreement terms.
• Use the StoreKit External Purchases or Offers entitlement (Japan storefront limited).
• Implement Apple-prescribed disclosure sheets (informing users they transact with the developer, not Apple).
• Comply with detailed UI, branding, typography, and layout rules.
• Integrate StoreKit eligibility and payment capability checks.

Apple warns that alternative payment flows may reduce access to App Store features like refunds, purchase history, subscription management, and Family Sharing.
 

Reporting, Audits, and Enforcement

Developers must:

• Track and report all alternative payment transactions monthly.
• Pay Apple-issued invoices within 30 days.
• Submit to Apple audit rights covering transaction records.

Non-compliance can result in offsets against developer proceeds in other markets, app removal, or termination from the Apple Developer Program.

Google Play in Japan: External Payments Program
 

Key Takeaway for Publishers

Japan allows external payment links on Google Play, but within a tightly controlled framework that preserves mandatory side-by-side billing, eligibility programs, attribution windows, and ongoing service fees. External payments in Japan do not provide full economic or operational independence from Google; platform dependency, reporting, and commissions remain. 

The Fine Print

Implementation Model: Eligibility-Based Program

External payment links are not permitted by default. Developers must enroll in and receive approval for the External Payments Program on a per-app basis. This is a controlled-access compliance model.

Eligibility Requirements

Participation requires:

• The app is a mobile or tablet app or game.
• External payments are offered only to users in Japan.
• The app does not target users under 13.
• The developer is a registered business entity.

Mandatory Side-by-Side Presentation
 

Google requires external payment links to be presented alongside Google Play Billing. Specifically:

• External-only payment flows are prohibited.
• Google Play Billing must remain available with external payments.
• Enrolled apps cannot use User Choice Billing.

This differs from the U.S., where standalone external payment links without parallel in-app billing are allowed.

Technical and Operational Obligations

Participating developers must:

• Enroll and receive approval for each app.
• Integrate with Google’s External Payments APIs (if available).
• Report all applicable transactions (including $0).
• Allow Google to surface required UX elements, parental controls, and disclosures.
• Provide customer support, refunds, and dispute handling.
• Ensure full compliance with Play Developer Policies.
• Avoid mentioning external purchases in Play Store listings.

Destination and UX Constraints
 

External payment links:

• Must direct users only to purchase the developer’s own in-app digital features or services.
• May lead to a developer-owned website or an installed payment app.
• Can only be shown after the user selects a specific digital item in the app.

External links must clearly disclose the destination/purpose before redirecting, avoid misleading redirects/deceptive information, and exclude personally identifiable information from URLs unless secured.

Fees and Attribution

External payment transactions are subject to Google service fees if completed within 24 hours of the user following the external link.

Applicable fees:

• 10% on auto-renewing subscriptions.
• 10% on the first $1M USD of annual eligible developer revenue.
• 20% on all other eligible digital content.

This creates a tiered commission structure up to 20%, despite the transaction being outside Google Play Billing.

What this means for publishers

Japan allows external payment links on both platforms, but within constrained frameworks. Eligibility programs, attribution windows, and ongoing commissions significantly limit margin upside.

Thus, the only model that maximizes margins by structurally removing platform commissions, attribution rules, and dependency on app-store payment policies is an independent web store. A fully web-based commerce flow operates outside app-store frameworks and enables full control over pricing, users, and monetization.