What Japan's Specified Commercial Transactions Act Requires on the Final Confirmation Screen for Subscriptions

When a team builds a signup flow for a subscription or a recurring delivery, the screen that causes the most debate is the one right before the order button.

Marketing wants the first month's price big. Legal wants every condition on it. The designer ends up in the middle, deciding font sizes.

That one screen has a role set by law. If you separate what is a matter of taste from what is not, the debate gets a lot shorter. I am a designer, not a lawyer. For specific decisions, check the original and your counsel.

The complaints are not going down

According to the National Consumer Affairs Center's page on recurring mail order purchases, consultations about recurring purchases of products bought by mail order or online were 80,315 in fiscal 2023, 89,401 in fiscal 2024 and 93,065 in fiscal 2025 (as of May 31, 2026).

The examples on that page read like a list of design decisions gone wrong. Someone ordered a supplement advertised at 980 yen for the first delivery and found they had signed up for seven deliveries. Someone ordered a cream from an ad that said "no minimum commitment" and a second delivery arrived anyway.

Materials the Consumer Affairs Agency presented to an expert panel on March 16, 2026 say that consumers most often notice they misunderstood the terms when the second delivery arrives. The agency is also still discussing dark patterns in online transactions.

What the final confirmation screen is

The amended Specified Commercial Transactions Act, in force since June 1, 2022, added Article 12-6 on what has to be shown at the point of ordering by mail order or online. The Consumer Affairs Agency's guidelines on displays at the ordering stage explain how it is read.

The guidelines call it the final confirmation screen: the screen where pressing the button completes the order. It does not need a title like "Confirm your order" to count. If card details are entered on a separate payment screen after it, the order review screen before that is the final confirmation screen.

Listing every condition on your ad or landing page is not enough. What matters is whether the final confirmation screen shows what it has to.

What goes on the final confirmation screen

The guidelines walk through six items that Article 12-6(1) requires:

• Quantity (for recurring purchases, the number of deliveries too)
• The price of the product or service
• When and how payment is made
• When the product is delivered or the service is provided
• The ordering period, if the offer is time-limited
• How to withdraw or cancel

For recurring purchases, you must clearly show the total amount the customer will pay, not just the price of each delivery. If the first delivery costs less than the rest, the later price has to be shown clearly next to the first. The guidelines give an example: a five-month contract that only shows one month's quantity is not showing quantity correctly.

If cancellation has conditions, those go on the final confirmation screen too. For example, how many days before the next shipment the customer must get in touch, or whether you only accept cancellations by phone. If you list a phone number, it has to be one that actually gets answered.

If everything does not fit on one screen, you may link to a page with details. The link has to be one the customer will clearly notice.

What counts as misleading

The guidelines also give specific examples to avoid. Here are the ones that land directly on design decisions.

Button labels. A screen titled "Order review" with a button that says "Confirm order" is generally fine. A button that says "Send" or "Next," with nothing else on the screen making clear this is an order, may mislead.

Size and placement. Making the first price big and putting the recurring terms in small text or far away. Putting the terms after an ad for some other product. Putting them below the order button. Each of these may be a violation if it leads people to think they are not signing up for recurring purchases.

"Trial" and "cancel anytime." Pushing words like "trial" hard when the purchase is actually recurring, or when cancelling is not easy, is described as strongly likely to be a violation. The same goes for "cancel anytime" when cancellation actually has conditions.

According to the guidelines, a consumer who orders because of a misleading display like these can rescind the order.

This applies to subscription apps and web services too

Mail order under this law covers services as well as products. If consumers sign up for a subscription on your own website, the safe move is to build the final confirmation screen the same way. Business-to-business deals are, as a rule, outside this law.

The guidelines mention subscriptions directly. If a free or discounted period switches automatically to paid or full price, you need to show in advance when it switches and how much the customer will pay.

With more apps moving payments to the web, more companies are building their own web signup screens. Put the first billing date, the amount, and how and by when to cancel right before the order button. That alone should cut a lot of the support requests that come after the second charge.

I wrote about the cancellation side in the piece on cancellation flows. The basic rule is to describe the same conditions in the same words on both the signup and the cancellation screens.

At the first meeting

If you are reviewing your signup screens, bring three things to the first meeting: screenshots of the whole current signup flow, the terms of your recurring plan or free trial, and the top three cancellation or refund questions your support team gets.

With those, I can show you on your actual screens which information to add and which emphasis to drop.