When Japan's Mobile Software Competition Act (MSCA) took effect on December 18, 2025, it quietly marked an inflection point that competition lawyers have been predicting for nearly a decade. For the first time, two of the world's largest economies — the European Union and Japan — now legally require Apple and Google to permit third-party app stores, alternative payment processing, and sideloading on their mobile platforms. South Korea's 2021 in-app payment law and the United Kingdom's Digital Markets, Competition and Consumers Act 2024 add further weight. The global app store gatekeeper model, in place since the iPhone's 2008 App Store launch, is being dismantled in real time.
This is a moment worth taking seriously — and a moment worth getting right. The case for opening mobile platforms is grounded in straightforward economics: when a single firm controls distribution to billions of users and extracts a commission of up to 30% on digital transactions, the deadweight loss is significant and the dynamic costs to innovation are harder to measure but plausibly larger still. But the case for proportionate regulation is equally strong. Mobile operating systems are not ordinary marketplaces; they are also the security and privacy perimeter for personal computing devices that now hold banking credentials, health records, and intimate communications.
What Japan's MSCA Actually Requires
The MSCA, administered by the Japan Fair Trade Commission (JFTC), applies to designated providers of mobile operating systems, app stores, browsers, and search. In practice, this targets Apple and Google. The Act prohibits a familiar list of gatekeeper practices: blocking alternative app stores, restricting developers from using third-party payment processors, banning sideloading, and engaging in self-preferencing across the platform. Penalties can reach up to 20% of relevant Japanese revenue for repeat violations — a meaningful number when applied to Apple's services revenue from one of its largest markets.
The structural similarity to the EU's Digital Markets Act is unmistakable. Both frameworks bypass the slow grind of case-by-case antitrust adjudication and impose ex ante obligations on a small set of designated firms. Both rely on a regulator to police compliance rather than waiting for private litigation to surface harms. And both reflect a political consensus — broadly across the spectrum in Japan, and across institutional lines in Brussels — that mobile platforms have become too important to be governed by their own terms of service.
The Early DMA Evidence
Two years into the DMA's enforcement, the results are mixed in ways that should inform Japan's implementation. Apple's initial compliance plan, which introduced a 'Core Technology Fee' on apps distributed outside its App Store, was widely criticized by developers including Spotify and Epic Games as a workaround that preserved Apple's economics while nominally complying with the law. The European Commission opened a non-compliance investigation, and Apple has since revised its terms multiple times. In April 2025, the Commission reportedly fined Apple €500 million for anti-steering violations under the DMA, signaling that formal compliance without functional competition will not satisfy regulators.
Meanwhile, the user experience of sideloading and alternative app stores in Europe has been underwhelming. Friction in installation flows, security warnings, and limited catalogues at alternative stores have meant that adoption remains modest. This is not necessarily an indictment of the DMA — competitive markets take time to develop, and incumbents have every incentive to make alternatives feel risky — but it does suggest that opening the platform is necessary but not sufficient.
Getting the Balance Right
From a pro-innovation perspective, Japan's MSCA is a reasonable response to a real problem. The 30% commission, applied uniformly to digital goods regardless of marginal cost, is difficult to justify on any model of competitive pricing. The prohibition on steering users to web-based payment alternatives — finally relaxed in the United States only after the Epic Games v. Apple litigation — was an anti-consumer practice that survived precisely because the platforms were not subject to competition. Forcing interoperability and choice in payment processing should yield lower prices and more experimentation, particularly for subscription services and small developers operating on thin margins.
But proportionality matters. The MSCA, like the DMA, should be enforced in a way that preserves the security and privacy properties users actually value. Specifically:
- Security baselines should remain robust. Sideloading is a legitimate user right; abandoning malware scanning, code signing, and runtime protections is not. Regulators should police the difference between security as gatekeeping and security as engineering.
- Compliance should be functional, not nominal. The Commission's pursuit of Apple's Core Technology Fee is the right model: if a rule is technically followed but commercially nullified, it has not been followed.
- Innovation in platform features should not be chilled. Rules against self-preferencing must distinguish between exclusionary conduct and ordinary product integration. Over-broad readings risk freezing platforms in place.
What Comes Next
The MSCA, the DMA, and the UK's emerging digital markets regime are converging on a shared regulatory grammar for mobile platforms. Brazil's CADE has signalled interest in similar measures; India's Competition Commission has investigations underway. The question is no longer whether app stores will be regulated but whether the regulation will be coherent across jurisdictions or fragment into a compliance maze that ironically advantages the largest firms — the only ones with the resources to navigate it.
The end of unilateral gatekeeping is, on balance, good for innovation and good for users. The hard work now is ensuring that the rules that replace it are the right rules, enforced with judgment, and harmonized across the democracies that have chosen to act.