On July 21, 2026, the Japan Association of New Economy (JANE) submitted a written response to the Call for Evidence conducted by the UK Competition and Markets Authority (CMA) regarding access to Near Field Communication (NFC) functionality on iOS.

【Background】
The CMA is currently considering the introduction of requirements to ensure that developers can provide contactless payment and other NFC-enabled services from their own applications, in light of Apple’s longstanding restrictions on third-party access to NFC functionality on iOS. JANE has consistently advocated that fair access to operating system functionalities, including those underpinning digital wallet services, is a central prerequisite for restoring competition in the mobile ecosystem. In Japan, the Mobile Software Competition Act (MSCA) and the Japan Fair Trade Commission’s guidelines, finalized in July 2025, explicitly identify conduct that impeding access to NFC functionality as an example of potentially prohibited conduct. JANE has also submitted detailed recommendations on NFC access throughout the formulation of those guidelines. Through this submission, JANE shares Japan’s experience in designing and implementing regulatory frameworks for mobile platforms in order to support policy development in the United Kingdom.

【Summary of Comments】
■On technical implementation (a dual-technology approach based on developer choice)
Access to NFC functionality should be ensured for both Host Card Emulation (HCE), a software-based solution, and Secure Element (SE), a hardware-based solution. The optimal approach depends on factors such as the intended use case, existing development assets, security architecture, and economic considerations. Developers themselves are best positioned to determine which technology is most appropriate. Regulators and platform operators should therefore avoid mandating a single technological pathway and instead allow developers to choose the solution that best meets their needs.

■On the pricing of NFC access
NFC access should be provided free of charge. The CMA itself has recognized that existing fees are likely to constitute a significant barrier to market entry. If fees are a key obstacle to entry, eliminating those charges is the most direct means of achieving the objective of regulatory intervention. The feasibility of free access is demonstrated by Apple’s existing practice of providing NFC access without charge within the European Economic Area (EEA). Even if some form of fee is permitted, it should be limited to a narrowly defined cost-based level. Value-based pricing that reflects Apple’s market power should not be permitted.

■On regulation based on substance rather than labels or formalities
The appropriateness of NFC-related charges should be assessed based on practical outcomes, namely whether businesses can realistically enter and compete in the market, rather than on formal labels or theoretical justifications. Regulators should prevent circumvention through mechanisms such as imposing multiple layers of fees under different names, outsourcing functions to third parties in ways that effectively increase costs, or recovering in the UK the costs associated with access that is provided free of charge in other jurisdictions.

■On the distinction between access and effective competition
A key lesson from the Japanese experience is that the formal existence of an access pathway does not automatically translate into effective competition. The CMA itself has noted that despite the formal availability of an access route, no new products or services have been launched over an 18-month period. The UK framework should therefore evaluate success on the basis of actual market entry and competitive outcomes rather than the mere existence of an access channel. This requires ensuring that the scope of accessible standards and use cases reflects market realities, including future payment, identity, and key-related services; that application procedures are predictable and timely; and that attempts to circumvent regulatory requirements are effectively prevented.

※ For the CMA’s Call for Evidence, please see here.
※ For the full text of the JANE’s submitted response, please see here.