Japan: Fair Trade Commission and Ministry of Economy, Trade and Industry adopted guidelines on Act on Promoting Competition Regarding Specific Software Used in Smartphones (Act No. 58 of 2024)

On 29 July 2025, the Fair Trade Commission (FTC) and the Ministry of Economy, Trade and Industry adopted guidelines on the Act on Promoting Competition Regarding Specific Software Used in Smartphones. The guidelines set out compliance requirements for designated business operators, targeting providers of mobile operating systems, app stores, web browsers, and search engines with significant market dominance. This dominance is assessed based on market share and the degree of dependency by users and developers. Dominant providers are prohibited from using non-public data from third-party apps or websites to compete against them. Unilateral conduct affecting app providers is banned, including discriminatory app review processes, unjustified delays or rejections of apps from alternative stores, preferential treatment of own apps in rankings or promotions, and restrictions on developers’ pricing, refund policies, or customer communications. The guidelines also prohibit app store and payment system restrictions, as well as manipulation of search engine rankings without objective criteria. Businesses must disclose data usage to users, ensure transparency in app review criteria, and establish complaint-handling systems. Operators must implement data interoperability for users and allow them to choose their operating system and browser settings. They are also required to disclose software specification changes and either allow users to reject them or explain why rejection is not possible. Finally, designated businesses must submit annual compliance reports to the FTC.