Japan’s Mobile Software Competition Act (MSCA): What mobile game developers should know

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Japan’s Mobile Software Competition Act (MSCA): What mobile game developers should know

December 19, 2025•6 min

Japan is among the first countries in Asia to formally challenge the market power of dominant mobile platform operators through sector-specific regulation. As the third-largest global market for mobile games and in-app purchases, Japan’s regulatory framework should be closely watched by developers, publishers, and platform operators worldwide. Starting December 18, 2025, the Mobile Software Competition Act (MSCA) has come into force. It sets new ground rules across the entire mobile ecosystem in Japan and, in turn, will address how Apple and Google operate their mobile operating systems, app stores, and related services in the market. To summarize the new regulation and policy and how it impacts you, here is a high-level overview of what the MSCA is, which parts of the law are most relevant to mobile games and direct-to-consumer (D2C) models, and how platforms have responded as of December 18, 2025.

What is the MSCA?

The Mobile Software Competition Act (MSCA) is Japan’s new ex ante regulatory framework for large mobile platform operators. Unlike traditional competition law, which typically acts after anti-competitive behavior occurs, ex ante regulation sets advanced rules that designated companies must follow. The MSCA applies to “specified software operators,” a category that currently includes Apple and Google due to their control over critical mobile infrastructure. The law regulates several core components of the mobile ecosystem, including:

Mobile operating systems
App distribution platforms (app stores)
Web browsers
Search services
Certain payment and billing services are linked to mobile platforms

The goal is to give developers a fairer, more transparent, and more competitive mobile ecosystem in which to build and grow. The MSCA serves two purposes 1. Sets limits on harmful platform behavior to prevent practices like:

Treating some developers unfairly or inconsistently
Blocking alternative app stores, browsers, or payment options
Stopping developers from telling users about other ways to purchase
Favoring a platform’s own services over third-party apps

2. Requires more transparency and predictability, by making platforms:

Be clearer about their rules and how they use data
Give advance notice of major policy changes
Apply review and compliance processes more consistently
These rules are intended to reduce uncertainty and address imbalances for developers.

How have platforms responded?

Following the MSCA's entry into effect, Apple and Google announced updates to their platform policies and technical frameworks in Japan. These changes focus primarily on app distribution, payment options, and user choice, and represent the first concrete implementations of the new law. Apple’s response Apple introduced a set of Japan-specific changes as part of its iOS 26.2 update, released last week:

Alternative App Marketplaces. Developers can now distribute apps through alternative app marketplaces outside the App Store. Apps distributed this way must still go through Apple’s Notarization process, which is designed to address security risks but is less extensive than standard App Store review.
Alternative Payments and External Purchases. Developers are now allowed to use third-party payment systems and/or link users to external websites to complete purchases, either alongside or instead of Apple’s in-app purchase system.
User Choice Screens. Users in Japan will be prompted to select their preferred default browser and search engine during setup.
Expanded OS-Level Choice. iPhone users can now configure the device’s side button to launch third-party voice assistants instead of Siri.

At the same time, Apple introduced a new set of business terms that apply different fees depending on where an app is distributed and how payments are processed:

App Store sales (in-app)
- 10% commission for Small Business Program members, specific partner programs, and subscriptions after the first year
- 21% commission for other digital goods and services
Apple payment processing fee
- If developers use Apple In-App Purchase, Apple charges an additional 5% payment processing fee
Web purchases linked from the app
- If an app links users to a website to complete a purchase, Apple charges a 15% commission on those web transactions
- This is reduced to 10% for Small Business Program members and qualifying subscriptions
Apps distributed outside the App Store
- Apps distributed via alternative marketplaces pay a 5% Core Technology Commission on digital good purchases and paid apps
- This fee applies regardless of the payment processor used

What this means for game developers While Apple has technically “opened” its platform, the new fee structures continue to uphold certain constraints. Here’s what developers need to know:

Linking to a web shop from an App Store app still triggers a commission. Even though the purchase is made online, Apple charges 10–15% on those transactions.
Web checkout can reduce fees, but not eliminate them. Compared to in-app purchases (which can reach 26% total when including processing), web flows may lower costs, but they are not zero-fee.

Google’s response Google’s updates build on Android’s existing support for third-party app distribution and are less extensive than Apple’s:

Expanded payment options for games. Google has removed prior limitations that restricted third-party payment systems mainly to non-game apps. Game developers in Japan can now use alternative payment providers and display them side by side with Google Play Billing. If the user elects a non-Google billing option, the service fee is reduced by just 4%.
External payment links with new service fees. Developers can now link out directly from within their app to web-based stores and payment destinations (like an Xsolla Web Shop) and are subject to service fees of 10% for auto-renewing subscriptions, 10% on the first $1 million of annual developer earnings, and 20% on all other purchases. All service fees apply to purchases made within 24 hours of linking out.
User choice screens. Google will begin rolling out browser and search engine choice screens within Chrome, giving users more control over default services.

What this means for game developers While the changes are positioned as expanding choice, they also introduce new costs and requirements. Here’s what developers need to know:

Despite this new regulation intended to open up mobile platforms, fees of up to 20% can apply to external payment links, and enrollment is required, which can subject an app to further scrutiny or approvals.

Final takeaway

While the MSCA sets the legal framework, it’s the platform updates that determine how much real flexibility developers actually get. The new regulations in Japan reflect a broader global trend – as we’ve seen with the EU’s Digital Markets Act – toward more competition and user choice. However, in practice, Apple and Google still attach fees and conditions to external payments, limiting true direct-to-consumer control without a tax. For developers, this means new options are emerging, yet the real leverage still depends on understanding the trade-offs and choosing when alternative distribution and payment paths make the most sense for their business. Xsolla is here to help you navigate these new regulations. Please reach out to schedule a meeting with our expert team. DISCLAIMER: This article is for general informational purposes only and does not constitute legal advice. Readers should not rely on this content as a substitute for professional legal guidance and should consult qualified legal counsel regarding the application of the MSCA to their specific situation.