Japan is quietly becoming the most decisive digital regulator in Asia. While the U.S. remains tangled in a web of appeals and conflicting court rulings, Japan’s Fair Trade Commission (JFTC) has passed the Act on Promotion of Competition for Specified Smartphone Software.
This regulation is designed to break the Apple/Google duopoly in the world’s third-largest IAP market. Compared to the EU’s DMA, which mandates broad openness, Japan’s policy is more deferential to the platforms’ claims of safety considerations, resulting in less favorable policy when it comes to side loading and alternative distribution. However, they are more explicitly skeptical of the specific fee price (30%) than Western regulators have been, so it is likely that Japanese courts will hear arguments that the status quo is unfair.
With full enforcement beginning December 18, 2025, now is the time for mobile game studios to understand what’s changing and how to capitalize on the D2C opportunity this opens up in Japan.
What is the Mobile Software Competition Act (MSCA)?
The Act on the Promotion of Competition for Specified Smartphone Software, commonly known as the Mobile Software Competition Act (MSCA), is a pro-competition law passed in 2024 to regulate the dominant mobile platform operators, specifically Apple and Google. The goal is to prevent anti-competitive behavior in app distribution and in-app payment processing.
The act focuses on four areas the government considers “specified software”:
- Smartphone operating systems
- App stores
- Web browsers
- In-app payment processing systems
What the MSCA requires
The law requires platform operators to open up key parts of the app ecosystem and prohibits practices that make it harder for developers to compete. This includes:
- Allowing alternative app stores - Apple and Google must permit third-party app stores to be installed and operated on smartphones in Japan without unreasonable restrictions.
- Allowing alternative billing - The platforms can no longer force developers to use their proprietary in-app payment solutions. Developers must be allowed to integrate alternative payment processors and link to external payment flows.
- Prohibiting self-preferencing - Platforms cannot give unfair advantage to their own apps or services in search rankings, recommendations, or app store visibility.
- Ensuring fair access to OS features - Gatekeepers must provide fair, reasonable access to APIs and device capabilities (for example, NFC, app store install prompts, browser choice screens) that were previously restricted or selectively granted.
- Improving transparency - The law requires clearer rules around app review, store policies, pricing and changes to terms.
- Enabling browser choice - Users must be able to select alternative browsers and browser engines. Apple, specifically, can no longer force the use of WebKit for iOS browsers.
Although the MSCA supports alternative app stores, it stops short of endorsing full sideloading, reflecting the regulator’s deference to security concerns.
What the MSCA unlocks for studios
Unlike the U.S.—where D2C progress hinges on court rulings and years of appeals—Japan’s approach is straightforward. The JFTC will enforce this law across both Apple and Google, with required compliance reports and regular audits to keep platforms in check. That clarity removes the uncertainty that clouded the post-Epic landscape.
In practical terms, the act unlocks meaningful, durable D2C opportunities in a top global IAP market.
- Native D2C payments: Studios can integrate payment SDKs directly into the game client. No more web-only flows; players pay inside the app with local methods.
- Direct links to webshops - Studios can inform players about payment options and offers available outside the app stores to drive traffic to webshops without fear of app rejection.
- Alternative distribution - White direct sideloading isn’t mandated, studios can launch versions of their games outside the App Store or Play Store, including via their own branded storefronts or publisher-run app ecosystems.
- Integration of web into native: The removal of WebKit restrictions on iOS enables complex games implementation, either as standalone web apps or integrated into native games.
Prepare for D2C in Japan now
When December 18, 2025 arrives, the studios that win will be the ones that treated this not as a compliance update, but as a commercial opportunity.
Japan is a unique market where players value security and ease of use. The "safety-first" nature of this Act—where sideloading is restricted but third-party stores are trusted—requires a specific D2C strategy.
Stash is built for this fragmentation. Whether you are leveraging the Epic v. Google ruling to sideload in the U.S., or using the Mobile Software Competition Act to launch a native third-party payment flow in Japan, our infrastructure scales with you.
If you’re ready to build your D2C plan for Japan, talk with our team today.
