2025 Japan Affiliate Marketing Compliance Guide: In-Depth Analysis of Specified Commercial Transaction Act Requirements

Introduction: Compliance — The Survival Baseline for Japan Affiliate Marketing in 2025

As the Japan affiliate marketing market matures, the Consumer Affairs Agency of Japan (消費者庁) continues to strengthen its regulation of online transactions. For any affiliate or advertiser hoping to achieve long-term, stable profits in the Japanese market, compliance is no longer optional—it's the baseline for survival.

Particularly regarding the latest requirements of the Specified Commercial Transaction Act (特商法) and the Act against Unjustifiable Premiums and Misleading Representations (景表法), these have become the core challenges for Japan affiliate marketing in 2025. Ignoring these regulations can not only lead to hefty fines but also result in promotional websites being banned and brand reputation being destroyed.

This article will provide an in-depth analysis of the 2025 Japan affiliate marketing regulatory environment, particularly the key impact of the Specified Commercial Transaction Act on affiliate marketing activities, and offer a practical compliance guide to ensure your business achieves sustained growth within regulatory frameworks.

Japan Market's Unique Regulatory Nature: Why Compliance Risks Matter More Than Revenue

Unlike some Western markets, Japanese consumers have extremely high expectations for information transparency and corporate social responsibility. Once complaints are filed or regulatory authorities take notice, negative impacts spread rapidly. The success of Japan affiliate marketing begins with establishing a trustworthy brand image.

Core Functions of the Specified Commercial Transaction Act and Its Relevance to Affiliate Marketing

The Specified Commercial Transaction Act (commonly known as 特商法) aims to protect consumer rights and regulate special transaction forms (such as door-to-door sales, telemarketing, online sales, etc.). Although affiliates themselves are not direct sellers of goods or services, promotional information, landing page design, and link redirects in affiliate marketing activities are all closely related to the Specified Commercial Transaction Act.

Four Core Requirements of the Specified Commercial Transaction Act for Affiliate Marketing

Although the Specified Commercial Transaction Act primarily constrains advertisers, in practice, affiliate promotion behaviors directly affect advertiser compliance. We must understand the four major requirements of the Specified Commercial Transaction Act from an affiliate marketing perspective.

1. Advertiser Identity Disclosure Obligation: Who is the Ultimate Responsible Party?

The Specified Commercial Transaction Act requires transaction parties to clearly disclose their identity information. In the Japan affiliate marketing system, this means:

Direct Sales Page Disclosure: The landing page where transactions ultimately occur (usually the advertiser's page) must have a clear "特商法に基づく表記" (Statement Based on the Specified Commercial Transaction Act).

Information Included: The advertiser's company name, responsible person's name, address, phone number, email address, and other key information must be publicly disclosed.

Affiliate Responsibility: When designing high-conversion landing pages, although affiliates don't need to provide their own Specified Commercial Transaction Act information, they must ensure users can smoothly and clearly navigate to the advertiser's compliant sales page. If the affiliate's pre-lander creates the misunderstanding that "the affiliate is the seller," they will bear joint liability risks.

2. Necessary Information Disclosure: Which Information Must Be Disclosed on Which Pages?

The Specified Commercial Transaction Act requires disclosure of all necessary information affecting consumer purchasing decisions during the sales process. Affiliate marketing promotional pages must pay attention to the accuracy of the following information:

Price, Payment Method, and Timing: Promoted prices must be consistent with the final sales page. For installment payments or regular purchases (定期購入), total costs and cancellation conditions must be clearly noted.

Return, Cancellation, and Refund Rules: Must accurately cite the refund/cancellation policies set by the advertiser.

Product or Service Delivery Time: Must clearly inform users when they will receive the product or service.

3. Prohibited False/Exaggerated Advertising: How to Define "Effect Guarantee" and "User Experience"?

This is the most easily violated area in Japan affiliate marketing, primarily subject to dual constraints from the Act against Unjustifiable Premiums and Misleading Representations (景表法) and the Specified Commercial Transaction Act.

The "Absolutely Effective" Trap: Absolutely prohibit using effect-guarantee language such as "guaranteed success," "100% returns," or "immediate cure," especially for health, beauty, and investment products.

False User Experiences: Even user testimonials must not use fabricated or exaggerated content. Promoters must ensure the objectivity of their promotional content, and any subjective experiences must be prefaced with "personal impressions" or "based on personal experience."

Image/Video Exaggeration: Avoid using Photoshopped or overly beautified images to imply unrealistic effects.

4. Cooling-off System and Its Relevance to Affiliate Marketing

The cooling-off system allows consumers to unconditionally cancel contracts within a statutory period for specific transactions.

Importance: Although most online sales don't apply to this system, for services with continuous provision, specific high-value transactions, or information sales, the Specified Commercial Transaction Act's cooling-off provisions may apply.

What Affiliates Need to Know: When promoting, affiliates must ensure they don't incorrectly convey false information such as "can cancel anytime" or "unconditional refund" to consumers. All information should be based on the advertiser's official statements.

2025 New Regulations and Industry Trend Outlook (JAO Study Group Background)

The Japan affiliate marketing industry is undergoing a compliance upgrade. According to study sessions organized by the Japan Affiliate Council (JAO) in 2025, regulatory trends point toward stricter information transparency and liability tracing.

Advertising Law and Specified Commercial Transaction Act Regulation Tightening: Boundaries and Penalties for "Stealth Marketing"

From late 2024 to 2025, one of Japan's regulatory focuses is stealth marketing (ステルスマーケティング).

Core Definition: Affiliates fail to clearly inform readers or viewers that their content has promotional nature, misleading consumers into thinking it's neutral, objective evaluation.

Increased Penalties: Once false advertising is confirmed, it not only faces administrative guidance but may even face fines. For Japan affiliate marketing practitioners, clear PR notation must be made at the top or prominent position of all promotional content.

Compliance Challenges and Risks for Affiliate Marketing on SNS/Content Platforms (such as Note, YouTube)

As traffic becomes centralized, affiliate marketing behaviors on SNS face stricter scrutiny.

Challenges: Platform restrictions (such as Note's restrictions on certain ads) and content review overlap, making compliance operations more complex.

Risks: If individual accounts violate regulations due to promotional content, they face account suspension and all affiliate income being clawed back.

Electronic Contract Law and Online Transactions: Impact on Japan Affiliate Marketing Processes

Japan's Electronic Signature and Certification Business-Related Laws are regulating the contract validity of online transactions. This requires advertisers to have absolutely standardized electronic contracts and purchasing processes when providing subscription services or long-term services. When promoting these services, affiliates must doubly confirm process clarity.

Practical Compliance Guide and Risk Avoidance for Affiliates

As promoters in the Japan affiliate marketing ecosystem, affiliates are the frontline for compliance implementation.

Compliance Design for Websites/Blogs (Half Moon Model): Perfect Integration of Privacy Policy and Specified Commercial Transaction Act Statement

A high-quality high-conversion landing page must focus not only on design but also on compliance module design.

Privacy Policy: Must clearly explain how the website collects, uses, and protects user data, especially when using tracking tools like Google Analytics and Meta Pixel.

Specified Commercial Transaction Act Statement Link: Although affiliates don't need to provide their own Specified Commercial Transaction Act information, they must clearly guide users in the promotional page (pre-lander) to view the advertiser's Specified Commercial Transaction Act page for transparency.

"Half Moon Model" Recommendation: In the footer or near the CTA button, display your privacy policy link, disclaimer, and advertiser's Specified Commercial Transaction Act link with extremely high readability to enhance trust.

How to Correctly Label "PR" or "Advertisement" in Articles: Subtle Differences in Japanese Culture

Correct labeling is key to avoiding stealth marketing risks.

Best Position: At the top of articles or SNS posts, use prominent colors or bold text to label "PR" (promotion) or "広告" (advertisement).

Clear Wording: Avoid ambiguous wording. For example, label "本記事はプロモーションを含みます" (This article contains promotional content).

Cultural Considerations: Audiences of Japan affiliate marketing highly value courtesy and transparency. Straightforward labeling is often more trusted than attempts to hide.

Self-Check List for Promoting High-Risk Products (such as Health Foods, Medical Aesthetics)

Efficacy Verification: When promoting efficacy-based products, must ensure their efficacy has been officially recognized by Japan's Consumer Affairs Agency or Ministry of Health, Labour and Welfare.

Avoid Exaggeration: Use qualifiers like "personal experience" and always avoid using exaggerated promotional language prohibited by the Specified Commercial Transaction Act.

Advertiser Compliance Management and the Role of ASP Platforms

Advertisers are the primary targets of Specified Commercial Transaction Act regulation, but their compliance also depends on the collective efforts of the Japan affiliate marketing system.

Advertiser's Content Review Responsibilities for Affiliates and Their Importance

Content Pre-review: Advertisers must pre-review affiliates' promotional copy and high-conversion landing pages, especially for expressions that may involve legal risks.

Violation Handling: Cooperate with ASP platforms to warn, suspend cooperation, or even terminate cooperation with affiliates who seriously violate regulations. This protects not only consumers but also the brand's own assets.

Auxiliary Role of Japan ASP Platforms (A8.net, ValueCommerce, etc.) in Specified Commercial Transaction Act Compliance

Mainstream Japan ASP platforms play an important role in ensuring compliance:

Violation Monitoring: Provide automated or manual monitoring services for violating promotional content.

Information Education: Regularly provide affiliates and advertisers with education and updates on the Specified Commercial Transaction Act and advertising laws.

Conclusion: Transform Compliance into Core Competitive Advantage for Japan Affiliate Marketing

The 2025 Japan affiliate marketing market is a market of transparency competition. Strict adherence to the Specified Commercial Transaction Act is not only an obligation but also the cornerstone for establishing brand authority (E-E-A-T) and achieving long-term high returns. A compliant, transparent promotional page can significantly enhance consumer trust, thereby improving conversion rates.

HALF MOON specializes in providing one-stop Japan affiliate marketing solutions for clients. We deeply understand that compliance and conversion rates are inseparable. Our high-conversion landing page templates and custom designs incorporate Specified Commercial Transaction Act and CRO principles from the start, ensuring your business achieves maximum ROI on a safe, compliant path.

If you have questions about Japan affiliate marketing compliance details or high-conversion landing page design, please consult HALF MOON. We provide professional compliance reviews and custom services to help you transform compliance into genuine business competitive advantage.