On April 15, 2026, Japan Association of New Economy submitted its comments on the “Compliance Reports under the Mobile Software Competition Act” filed by Apple Inc., iTunes K.K., and Google LLC, which were published by the Japan Fair Trade Commission on February 17, 2026.

[Summary of Comments]

Comments to Apple Inc., iTunes K.K., and Google LLC
■ Regarding all fees imposed by designated operators on app developers—such as those for alternative payment methods and external payments via link-outs—the compliance reports should provide detailed explanations regarding the reasons for imposing such fees, the methods used to calculate them, and the reasonableness of their levels.

■ The practice of requiring app developers to implement the designated operator’s payment system as a condition for implementing alternative payment methods or external payments via link-outs should be discontinued, and this should be clearly stated in the compliance reports.

Comments to Apple Inc. and iTunes K.K.
■ In the compliance report, the concept of “comprehensive grounds for justification” — created by adding the protection of intellectual property rights to the legally established justification grounds, as if such protection also constitutes a justification ground — should be abandoned.

■ The statement that app developers’ use of OS features is left to “Apple’s discretion in line with Apple’s commercial strategy and priorities” should be removed.

■ App developers’ use of OS features should be made available free of charge.

Comments to Google LLC
■ The Compliance Report should clearly state that participation in the External Payments Program is not required for the development of apps that direct users to external payment services using text strings only.

*For the full text of the submitted opinions, please click here(in Japanese only)
*For details on the Compliance Reports, please click here (in Japanese only)