Do foreign SaaS companies need a 特商法 page to sell in Japan?

If you sell an online subscription, license, or digital product to customers in Japan, you're doing 通信販売 (mail-order / distance selling) under the Act, and the disclosure is expected. A few rules of thumb:

• B2C SaaS / any consumer-facing paid product → yes, clearly. This is the core case the law is written for.
• B2B SaaS → still expected in practice. Japanese companies running you through procurement look for it, and its absence is a quiet disqualifier even where the strict legal need is debated.
• Completely free product, no payment from Japan → generally not required — but the moment you add a paid tier that a Japanese customer can buy, it applies.

In four years of looking at foreign software for the Japanese market, the share of paid foreign tools that have a 特商法 page is close to zero. It is the most consistent gap there is.

The 特商法に基づく表記 page is expected to disclose, at minimum:

• Seller's legal name (販売事業者) and the name of the responsible person (運営責任者)
• A physical address (所在地) and a phone number (電話番号) reachable for inquiries
• Selling price and what's included, plus any additional fees (consumption tax, etc.)
• Accepted payment methods and the timing of payment
• When the service is provided / delivered
• Cancellation, refund, and return terms (返品・キャンセル)

It's normally a plain page, in Japanese, linked from the footer. Nothing fancy — but the fields are specific, and a vague or English-only version doesn't carry the same weight with a Japanese reviewer.

The address and contact fields are where being foreign bites. A page that lists only a San Francisco or Berlin HQ address and an English support email technically fills the boxes, but to a Japanese buyer — and often to a Japanese payment processor reviewing your account — it reads as "not actually set up to operate in Japan." Two things tend to matter in practice:

• A reachable contact that works in Japanese — a phone number and an inquiry path a Japanese customer can actually use.
• A credible address — many foreign companies use a Japanese representative, a local agent, or a registered address service so the field reads as legitimate rather than "head office is overseas, good luck."

This is exactly the kind of thing that doesn't show up in a translation pass. The page can be perfectly translated and still read as non-compliant because the underlying setup is foreign. It's why 特商法 is less a localization task than an operations one — and the part a native catches that a translation tool can't.