Japan's Consumer Affairs Agency has opened a public comment period, running from September 16 to October 31, 2026, on an interim report that would rewrite how the Specified Commercial Transactions Act treats online selling, and the proposals go well beyond tidying up disclosure labels. The Digital Transactions and Specified Commercial Transactions Act Study Group, which met nine times between January and September 2026, wants unsolicited sales pitches sent through chat apps, direct messages and short message services to face the same legal regime as telephone solicitation.
Under the proposal, a business that opens a one-on-one chat to pitch a product, or lures a consumer into starting that chat without disclosing its sales purpose, would have to state the seller's name, the solicitor's name, the type of product and the sales purpose before pitching. Lying or omitting material facts would be banned, as would intimidating or distressing conduct, and re-soliciting someone who has already said no would become illegal, mirroring existing phone-sales rules. Consumers would get an eight-day cooling-off window from receipt of contract documents.
| Practice targeted | Proposed treatment |
|---|---|
| Chat/DM sales pitches | Apply telephone-solicitation-style disclosure, cooling-off and re-solicitation bans |
| Subscription traps and fake urgency displays | Ban misleading UI on price, quantity, contract term and fabricated stock/review claims |
| Checkout confirmation screens | Require full-price display, ban split pricing across screens, mandate post-order e-document |
| Return-policy refusals | Bar sellers from citing return clauses without checking underlying facts |
| Slow or complex cancellation procedures | Make delay and needless complexity an enforcement target |
| Web ads luring shoppers to stores | Reclassify as door-to-door sales requiring purpose disclosure |
| Bait-priced callout repair services | Illegal only when a false advertised price lures a visit into a pressured, hard-to-leave environment |
| Late-disclosed multi-level marketing | Treat as multi-level marketing from the point of the original sale contract |
The report also takes aim at so-called dark patterns: interfaces that make a one-time "trial" purchase look ordinary while burying the fact that it is really a recurring subscription, or that use fake stock counters, fabricated reviews and repeated pop-ups to pressure a purchase. The study group wants a broad, technology-neutral prohibition on displays that mislead consumers about price, quantity or contract term, or that use aggressive tactics to push an unwanted order, alongside a ban on displays that are hard to recognize as advertising and a requirement that displays not obviously identifiable as ads carry a clear advertising label.
Final-confirmation checkout screens would face tighter rules too: full payment totals could no longer be split across multiple screens to obscure the real cost, and sellers would have to send a durable electronic copy of the contract terms promptly after an order is placed, giving consumers something to point to if they later dispute a charge. Separately, the report would bar sellers from citing a return-policy clause to refuse a refund without first checking the underlying facts, and would make deliberately slow or needlessly complicated cancellation procedures an enforcement target in their own right.
Outside pure online sales, the report would close a loophole that lets web ads do what paper flyers already cannot: a website advertising a bricks-and-mortar location that lures a consumer into visiting the store, without disclosing that a sales pitch will follow, would be reclassified as door-to-door sales and made subject to the same purpose-disclosure duties that already apply to in-person doorstep solicitation.
The study group also wants a specific illegal-act designation for so-called rescue-service tactics: a business that advertises a materially false price or fee online, induces a visit request based on that price, and then, in a setting that makes it hard for the consumer to bring in outside help, leave the solicitation or compare alternatives, solicits without reasonable grounds a contract priced far above the advertised figure, would face administrative enforcement as illegal conduct. The report would also extend multi-level-marketing obligations to schemes that only disclose the multi-level structure after an initial sale has already been made, treating the arrangement as multi-level marketing from the point the original sale contract was signed rather than from whenever the recruiting layer becomes explicit.