What is Japan’s Mobile Software Competition Act (MSCA)?

Japan’s Mobile Software Competition Act (MSCA) is a regulation that modifies how Apple and Google organize their app distribution and payment services in Japan. The act specifies that developers can use alternative app stores, select alternative payment methods, and process transactions through channels other than those originally provided by the platform, moving off default platform billing and onto substantially lower commission tiers. With these changes, developers and publishers in Japan need to review and adjust their operational practices to follow the MSCA’s requirements.

The MSCA includes specific requirements for “designated providers,” which are defined as platforms with more than 40 million monthly users in Japan. In March 2025, the Japan Fair Trade Commission (JFTC) selected three organizations to fall within this category:

• Apple Inc., covering its operating system, App Store, and browser
• iTunes K.K., which is Apple’s subsidiary in Japan and works jointly on the App Store in Japan
• Google LLC, listed for its operating system, Play Store, browser, and search engine

The MSCA sets out ex-ante regulation – rules that are intended to regulate market practices in advance of potential concerns, rather than punishing it after the fact. These rules apply to selected providers based on specific criteria:

The MSCA and the EU’s Digital Markets Act (DMA) are both examples of regulatory efforts concerning digital platforms. While they share the same ex-ante philosophy, there are several differences between them:

• Security first: The MSCA contains provisions permitting Apple and Google to implement certain restrictions pertaining to cybersecurity or user privacy, while the DMA prioritizes widespread platform access.
• 范围: The MSCA is specific to smartphone-related platforms in Japan, whereas the DMA applies to a broader group of digital services.
• Native payments: The MSCA outlines how third-party payment providers can be embedded as a built-in feature within applications – not just linked out to a web page.

Both Apple and Google provided updates about compliance steps on December 17-18, 2025, aligned with the start of the MSCA.

Apple adjusted iOS 26.2 to meet requirements set for Japan:

• Use of alternative app marketplaces is permitted on iOS devices in Japan.
• Applications distributed outside of the App Store must complete Apple’s Notarization verification process, which is less extensive than the standard review.
• Third-party payment processing is permitted within App Store applications.
• Apple reduced its standard 应用内购买 commission in Japan from 30 to 26%.
• Apple’s commission now varies by route: 21% for third-party payments inside App Store apps (10% for Small Business Program members and subscriptions after the first year), 15% on purchases completed via a linked website (10% for SBP), and a 5% Core Technology Commission for apps distributed outside the App Store.

Google made changes specific to Japan that added options for browser and search engine selection, as well as alternative in-app payment methods for digital purchases for users in Japan.

AltStore was released on iOS the day the MSCA took effect, and the Epic Games Store announced its Japan launch for January 2026.

Japan is the third-largest global market for mobile games and in-app purchases, with approximately 70% of surveyed Japanese smartphone games making use of external payment systems. Under the MSCA, several procedural and operational changes are relevant to developers:

• Lower commission costs: Developers can choose to use third-party billing solutions instead of Apple or Google’s standard options, which may result in different commission rates than the previous default range of 15–30%. Every alternative route carries a lower platform take than default In-App Purchase: 21% for in-app third-party billing, 15% for web-linked purchases, and 5% for apps distributed outside the App Store.
• Customer relationship ownership: Direct billing means developers control the transaction, customer data, and subscription relationship – not the platform.
• D2C strategies under legal provisions: Developers may display pricing and promotional information on their own websites and organize transactions through direct sales or App2Web and D2C monetization flows.
• Unified cross-market strategy: Since the MSCA has provisions related to those in the EU DMA and recent US legal developments, developers may build alternative billing infrastructure across markets.

The saving is real but not automatic: a lower platform rate only converts into margin if processing, tax, FX, 退款, and chargebacks are handled efficiently on the other side.