Japan's Mobile Software Competition Act: Legal Implications for Game Publishers

Japan’s new Mobile Software Competition Act will fundamentally change how global publishers operate in the world’s third-largest gaming market. Beginning December 18, 2025, Apple and Google must allow external payments, third-party app stores, and web store promotion inside apps, creating entirely new pathways for DTC monetization. Below, we break down what the law requires, how regulators expect platforms to behave, and what publishers should prepare for now.

Background 

Historically, Japan's mobile application ecosystem mirrored the global duopoly, wherein Apple and Google maintained tightly controlled platforms governing both application distribution and in-app payment mechanisms. Specifically, the iOS platform prohibited sideloading and mandated the use of Apple’s proprietary billing system for in-app purchases, subject to a commission rate ranging from 15% to 30%. While the Android operating system theoretically permitted the installation of third-party applications, Google Play dominated the market and enforced comparable billing stipulations.

Legislative Change: The "Act on Promotion of Competition for Specified Smartphone Software"

In June 2024, the Japanese Diet formally enacted the "Act on Promotion of Competition for Specified Smartphone Software"; hereinafter: the "Mobile Software Competition Act"). 

This legislation is scheduled to take effect on December 18, 2025, and is specifically directed at dominant providers of mobile operating systems, application stores, web browsers, and search engines. The Japan Fair Trade Commission (JFTC) has officially designated Apple and Google as "Specified Providers."

Key obligations stipulated by the Act include:

• A ban on anti-steering provisions, thereby permitting developers to direct users to external websites or alternative payment methods, including via visible buttons and pricing information inside the app
• Mandatory support for third-party app stores and sideloading, provided that reasonable security requirements are met, and without hidden settings, delays, or additional fees that undermine viability
• Prohibition on requiring the exclusive use of proprietary payment systems, and a ban on charging commissions or imposing friction for external payments
• Equal access to essential OS functionalities (e.g., Near Field Communication (NFC), Application Programming Interfaces (APIs)) and a prohibition against self-preferencing in search results or rankings, including obligations to firewall sensitive third-party data
• Ensuring user freedom of choice for default applications and browser engines, including the removal of WebKit restrictions on iOS and a mandatory choice screen during device setup.

JFTC Guidelines: Clarification of Compliance Expectations

In mid-2025, the JFTC released comprehensive Guidelines designed to clarify the expected standards of conduct. Notable aspects include:

• Explicit prohibition of methods to block or discourage third-party stores or payment systems through obscured settings, additional charges, or ambiguous security policies
• Restriction of security and privacy measures to those that are narrowly tailored and demonstrably necessary
• Requirement for developer data firewalls separating platform services from competing offerings
• Mandate for annual compliance reports

The Guidelines further explicitly caution against "creative compliance" tactics, such as imposing excessively burdensome approval processes or neutralizing the benefits of the law through offsetting costs. Apple’s prior conduct in the Netherlands (e.g., the imposition of service fees on dating applications using external billing) is cited as an example of impermissible behavior.

Apple’s Response: Cautious Compliance

Apple has indicated acceptance of the legislation but continues to emphasize the importance of user privacy and security. By November 2025, Apple released iOS 26.2 beta in Japan, which facilitates the installation of third-party application stores (e.g., AltStore PAL, Epic Games Store). 

However, as of late November, Apple had not yet formalized updates to its App Store Review Guidelines concerning third-party billing or external payment links. Based on past practice, Apple may require a registration or entitlement process. However, under the Act and the JFTC Guidelines, it is prohibited from imposing significant fees or burdensome procedural hurdles. We will therefore need to see how exactly the mechanism Apple implements will look in practice.

Google’s Response: Quiet Alignment

Google has issued fewer public declarations. Given that the Android platform is inherently more open, modifications will primarily concentrate on the elimination of discouraging User Experience (UX) patterns and the formal permission of alternative billing and external payment links within Google Play. 
 

Scenario Analysis

• Full Compliance: The widespread adoption of external payments and third-party stores is realized, stimulating increased price competition and fostering innovation.
• Creative Compliance: Apple and Google adhere to the letter of the law but introduce friction through security prompts or restrictive eligibility frameworks. Such strategies will be subjected to scrutiny against the JFTC’s established standards.
• Market Impact: Developers may bypass established store fees. Apple and Google may consequently respond with reduced commission rates or enhanced incentives to retain transactions within their proprietary payment systems.
   

A New Operating Reality for Japan

Commencing December 18, 2025, Japanese law will legally mandate a more open and competitive mobile application ecosystem. The legislation and its subsequent implementing guidelines substantially curtail the ability of Apple and Google to restrict the utilization of alternative payment systems or application stores. 

While initial implementation friction is probable, the legislative intent is unequivocal: developers all over the world with players in Japan will soon possess unprecedented operational flexibility.

Appcharge is fully prepared to help our partners capitalize from day 1 and we're paying close attention to the developments. Get in touch to learn more.