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Freedom251 › Blog › app competition

What Japan’s Smartphone Act Means for Apple—and the Fairness Complaint

By Freedom251 Team · · 3 min read

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Japan’s Smartphone Act has been fully in force since December 18, 2025. Apple’s July 2026 compliance report describes the company’s own measures; Japan’s Fair Trade Commission (JFTC) says the report is not its assessment of compliance. A news outlet also reported a Coalition for App Fairness complaint, but that complaint is not a JFTC finding.

What Japan’s Smartphone Act covers

The formal name is the Act on Promotion of Competition for Specified Smartphone Software, Act No. 58 of 2024. Japan passed it on June 12, 2024, and promulgated it on June 19, 2024. The JFTC describes its purpose as promoting competition and innovation in software important to smartphone use while protecting security and privacy.

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The Act covers four categories: mobile operating systems, app stores, browsers and search engines. Its provider-designation provisions took effect before the rest of the law. On March 26, 2025, the JFTC designated Apple Inc. for mobile operating systems, app stores and browsers; iTunes K.K. for app stores; and Google LLC for all four categories. The Act as a whole took effect on December 18, 2025.

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How the rules are organized

The JFTC’s July 2025 guidelines describe prohibited conduct in Articles 5–9 and compliance measures in Articles 10–13. The guidelines are a tentative English translation; the official Japanese legislation is the source for the exact statutory wording. The JFTC also cautions that its hypothetical examples are illustrative and that applying the Act depends on the circumstances of each case.

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What Apple’s compliance report establishes

On July 27, 2026, the JFTC published designated providers’ reports for FY2025, which for this reporting period means December 18, 2025 through March 31, 2026. Business secrets were excluded from the published versions. Apple’s report is therefore an account of the measures Apple says it took during that period—not an independent certification that those measures satisfy the Act.

The JFTC stated that the published reports “only represent the views of the designated providers, and do not represent the views of the JFTC.” The public information described here does not establish the detailed contents of Apple’s measures, so it would be misleading to attribute particular policy changes or technical safeguards to the report without the report itself.

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Why the JFTC’s distinction matters

The JFTC had made the same distinction when discussing initial reports on February 18, 2026. It said it would examine effects on businesses in the covered software categories and consider views from relevant businesses and other stakeholders. Publishing company reports is part of that process; it is not a decision that a company complied or violated the law.

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What the fairness complaint says—and what remains unconfirmed

The Mac Observer reported on September 13, 2026 that the Coalition for App Fairness submitted a complaint to the JFTC on August 21. The outlet characterized the coalition’s position as arguing that Apple’s report demonstrated an unwillingness to comply. That is a secondary account of the complaint, not a regulator conclusion.

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The complaint’s primary text was not available in the sources for this account. Its exact wording, signatories, supporting evidence and requested remedies therefore cannot be verified here. Nor is a subsequent JFTC response established. Specific allegations beyond the news outlet’s characterization should not be treated as confirmed.

Has the JFTC ruled that Apple violated the Act?

The JFTC’s publication of Apple’s report and its invitation for stakeholder input do not amount to a violation finding. The JFTC invited opinions about the reports and the law’s market effects, and it maintains a separate channel for suspected statutory violations. It cautions that an individual submission does not guarantee the action a submitter seeks. The information available for this account does not establish a JFTC ruling that Apple violated the Act.

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How to assess the dispute as it develops

A useful assessment needs more than a company’s description of its own compliance or a complaint reported by a news outlet. The relevant questions are:

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  • Which specific statutory duty is at issue?
  • What measure does Apple say it adopted to meet that duty?
  • What evidence supports the company’s account, and what do developers or other stakeholders report about their experience?
  • What are the practical effects on developers and users?
  • If Apple relies on security or privacy, is that rationale specific to the measure in question?
  • What independent assessment or subsequent action does the JFTC publish?

The JFTC’s guidelines call for case-specific analysis and expect reports to explain measures and provide supporting evidence. Until the regulator assesses the evidence and explains its position, Apple’s report, the coalition’s reported complaint and an official finding remain distinct kinds of information.

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