The Japan Fair Trade Commission and the Small and Medium Enterprise Agency said on 7 October 2026 that they are convening a corporate transactions study group, a sign that they do not consider the recent round of rule-writing to be enough. The group is a forum for discussion, not a new enforceable rule, and the release makes no finding against any company.
The rulebook so far
The release says the new group follows an earlier study group report from December 2024. The authorities say they responded to the problems that report raised with a string of measures, listed below.
| Measure | Enacted or published | Takes effect |
|---|---|---|
| Subcontract Act amendment | Enacted May 2025 | January 2026 |
| Logistics special designation amendment | Published June 2026 | April 2027 |
| Payment notice | Published June 2026 | April 2027 |
| Abuse-of-superior-position guidelines revision | Published June 2026 | Not stated |
| Intellectual property transaction guidelines | Published June 2026 | Not stated |
Several of these have yet to bite. The logistics designation and the payment notice both take effect in April 2027, according to the release.
Why the agencies say it is not enough
The stated rationale rests on two government surveys: the SME Agency's follow-up survey to its price negotiation promotion month, and the Fair Trade Commission's special survey on efforts to facilitate price pass-through. Based on their results, the agencies say there are still problems on three fronts. Businesses have been slow to adopt the rules. Price pass-through is less advanced the deeper a company sits in the supply chain. And commercial practices that obstruct price pass-through and fair dealing have been identified in individual industries. The release frames these as conclusions the agencies draw from the surveys, and it gives no survey figures.
The study group's stated task is to identify issues concerning abuse of a superior bargaining position and the related transaction law, then consider concrete measures. The agencies say the aim is to change corporate behaviour and put it into practice, and to improve commercial practices further.
Who sits on it, and how it works
The group is co-hosted by the Fair Trade Commission secretariat and the SME Agency. Members come from academia, law firms, manufacturers and business and labour bodies, including the Japan Business Federation, the Japan Chamber of Commerce and Industry and the Japanese Trade Union Confederation. A University of Tokyo professor emeritus chairs it. The Financial Services Agency and the ministries for internal affairs, agriculture, economy and trade, and land and transport attend as observers.
Meetings will be closed, which the agencies say is meant to encourage free and open exchange among members. They promise to publish minutes promptly. The release gives neither a first meeting date nor a timetable for recommendations, so the minutes are the first place purchasing and supplier-compliance teams can expect to see where the debate is heading.