Payment withholding disclosures: what Japan’s Transparency Act requires

Japan’s rules require designated digital platforms to disclose conditions for withholding payments. The Platform Council sees that transparency as a useful step, while its adopted standard calls for broader safeguards when a platform holds funds or changes a business account.

What happened

Japan’s Act on Improving Transparency and Fairness of Specified Digital Platforms requires designated platforms to disclose conditions including those for withholding payments.[1]

Japan’s Act applies to designated specified digital platforms, including online malls, and requires disclosure of transaction conditions that include conditions for withholding payments.[1][2]
The Ministry of Economy, Trade and Industry identifies designated online malls including Amazon Japan, Rakuten Ichiba, Yahoo! Shopping and Qoo10.[2]
The EU provides a different, related case: its Platform-to-Business Regulation requires statements of reasons in certain cases of restricting or suspending a business user, and advance notice before terminating the whole service.[3]

What it means for small businesses

A published withholding condition gives a business owner information about the platform’s stated rules, but disclosure alone does not ensure a specific reason, human review or a deadline for releasing that owner’s funds.

Coverage depends on the jurisdiction and the platform’s designation or legal status; owners should not assume a rule that applies in Japan also protects them elsewhere.

The Council’s adopted standard calls for written notice, a specific reason, review by a person and a time limit on payout holds, with the same protections in every country where a platform operates.