[Effective December 2025] How will off-app purchases change with Smartphone Act? Expert Thorough Analysis of Fee Reduction Strategies and Essential Security Requirements

On December 18, 2025, the "Act on the Promotion of Competition Related to Specified software Used in Smartphones" (abbreviation: Smartphone software Competition Promotion Act, hereinafter referred to as "Smartphone Act") will finally come into full effect.

This law, which introduces the principle of competition in app stores and payment markets that have been dominated by giant platforms such as Apple and Google, has the potential to fundamentally change the business model for app operators. The biggest focus is on avoiding the 30% in-app purchase fee, which has been a burden for app operators for many years, and the dramatic improvements in revenue model that come with it.

But with choice comes responsibility. The lifting of the ban on non-app purchases (Web payment) means that operators must take the security measures that platforms have been responsible for so far.

From the heart of Smartphone Act to strategies to maximize fee reduction and the security requirements essential for safe implementation, Shogo Suzui from the GMO Payment Gateway (GMO-PG) Industry Solutions Division explains.

GMO Payment Gateway, Inc. Industry Solutions Division 1st Sales Department General Manager of Service 1st Sales Department 　 Shogo Suzui After working in domestic venture capital, he joined GMO Payment Gateway in 2013 and was in charge of sales to small and medium-sized product sales sites and cart vendors. Currently, he leads a wide range of departments such as online games, digital content such as e-books and audio, and service commerce (intangible goods) such as food delivery, as well as tech startups, BtoB business, and publishing.

The Core of Smartphone Act: Promoting Competition and Regulating Giant Platformers

The aim and target of the law "Specific software"

Smartphone Act aims to ensure a level playing field in the software (operating system, app store, browser, search engine), which is essential for smartphone use. Specifically, the Fair Trade Commission has designated three companies, Apple Inc., iTunes Inc., and Google LLC, as designated operators, and they are required to prohibit preferential treatment of their own services and open them to third parties.

*Reference: Fair Trade Commission "(March 31, Reiwa 7) Designation of Specified software in the Act on the Promotion of Competition software Related to Specified Used in Smartphones"

"Two impacts" that will change the app business

With the enforcement of this law, there will be two major changes (impacts) in the business of app operators.

1. Unlocking Out-of-App payment (Fee Avoidance)
   Previously, in-app purchases (IAPs) were required and incurred fees of up to 30%, but due to regulatory changes, third-party payment method other than in-app purchases (IAPs) will now be allowed to be selected and implemented under the terms and conditions set by the platform. This allows you to reduce the fees you pay to your platformers by implementing your own payment system.
   
   
2. Fair use of OS functions and prohibition of in-house preferential treatment
   ​Important OS functions and interfaces such as NFC and biometric APIs, which were previously exclusively used by platformers, will be opened up to third-party operators on fair and non-discriminatory terms. This will enable operators to aim for the same functions and performance as the services provided by the platformer. In addition, platformers are prohibited from unfairly favoring their services and products in all aspects of the platform, such as app store rankings, ensuring a level playing field.

The full picture of "off-app purchases" that will transform revenue model

Free from 30% fees and improve profit margins

The biggest benefit for app operators is cost savings. In some cases, the payment fee for in-app purchases (15-30%) compared to the fee for in-app purchases (web payment) may be reduced to a few percent. This difference can be used as a source of profit improvement and return to users.

Experts talk about "coexistence of in-app and off-app billing"

Should low fees mean you should move all payment out of the app? Suzui of GMO-PG, who has been involved in the payment of the service e-commerce industry including digital content for a long time, recommends building a coexistence environment.

▲GMO-PG Shogo Suzui

"This law presents a huge opportunity for app operators to improve their revenue. However, even if off-app purchases are actively promoted, we believe that in-app purchases will not completely disappear from the perspective of usability for users (end users). At GMO-PG, we aim to create an environment where in-app purchases and off-app purchases can coexist well while also having the perspective of the end user beyond that, rather than unilaterally promoting off-app purchases from the perspective of operators."

The "ease" of in-app purchases and the "benefits" of payment outside the app. It is necessary to determine the balance between these two and design in a way that allows both users and businesses to enjoy the benefits.

Practical Strategies to be Taken in Smartphone Act Enforcement

After the full implementation of Smartphone Act (December 18, 2025), it is expected that direct links (direct guidance) from within the app to billing websites, etc. will be lifted. However, even before the enforcement, it is possible to obtain the fee reduction effect in advance by "indirect induction outside the app" to the extent that it does not conflict with the terms of Apple and Google.

The "20% rule" that leads users to the web store

The key to the success of off-app purchases lies in whether you can provide users with benefits that outweigh the hassle of "going out of their way to the web and payment".

According to a user survey conducted by GMO-PG, the most attractive benefit (67.0% support) is that "you can buy cheaper than through the store". Specifically, there is data that shows that about 40% of users show their intention to use off-app purchases by offering "a few %~20% discount or item increase".

Q.When using "off-app purchases", please choose all of the following (what benefits do you find attractive to those who have used it?).

*Source: Consumer off-app billing survey 2025 GMO-PG survey (N=795)

Effective guidance techniques

In principle, it is prohibited to link directly from within the app to the payment screen before the new law comes into effect. Therefore, the following indirect approaches are effective, keeping in mind even after enforcement.

• Announcement on official SNS and website: We will promote "web store exclusive special packs".
• Clarification of incentives: Emphasize the advantages of using the web, such as "20% increase in diamonds on the web" and "granting limited items". Major titles have already been induced by "increasing the amount of items" and "price discounts".

Implementation pattern comparison and required security measures

The introduction of off-app billing can be broadly divided into two patterns: "in-house billing site construction type" and "external platform (PF) participation type".

Implementation pattern comparison: in-house vs. external platform

You need to choose the best technique according to your business scale and resources. Of course, it can also be used together.

For small businesses and those who want to start small, the "external PF participation type" is advantageous because it requires less development man-hours and can be entrusted with attracting customers from game media. On the other hand, for major businesses that want to unify the UX including the brand's worldview and the payment method they can use, and reduce fees as much as possible, the "in-house built" type is suitable.

"Security risks" that cannot be ignored

When it comes to off-app purchases, users are most concerned about "security and handling of personal information" (47.7%).

Q.If you have any concerns or concerns about "off-app purchases", please select all of them from the following.

*Source: Consumer off-app billing survey 2025 GMO-PG survey (N=795)

As long as you move away from the protection of the platform, the following measures are essential:

1. Building a PCI DSS-Ready payment Site: Meeting the Credit Card Industry's International Security Standards
2. Non-retention of credit card information: A system that uses link-based connections and Tokenization to prevent card information from passing through or storing on the company's server.
3. fraud Countermeasures: Fraud detection systems and EMV 3-D secure (identity authentication)

It is not easy to maintain these on your own. Therefore, consult with a trusted payment processing company company (PSP) to understand what you need to do and what other companies, including the payment processing company company (PSP), can support.

Reasons for choosing GMO-PG: Security, stability, and comprehensive strength

payment processing company When choosing a company (PSP), it is dangerous to choose only because of the "low fee". The stability of the business foundation is essential to avoid the risk of lost opportunities due to system downtime or lack of capacity, bloated development costs, and loss of sales due to deteriorating payment company's cash flow.

The reasons why GMO-PG is chosen by many app operators can be summarized in the following three points.

(1) Support for "Seven Stars" certification and a strong sales system

payment is directly related to sales, so it is most important to "connect immediately" in case of trouble. GMO-PG has a support center that has received a three-star rating of HDI Support Center Certification (7-star certification) and the HDI rating benchmark "Quality Rating" (multi-channel).

In addition, we have approximately 200 sales employees based in Tokyo, Osaka, and Fukuoka, and we can work closely with people who are familiar with the industry and industry, both face-to-face and online. This two-sided system of "sales × support" provides a sense of security that other companies do not have.

(2) Overwhelming "stability" that supports large-scale transactions

During events of popular games and the sale of rare items, a large number of visits are concentrated in a short period of time.

GMO-PG stably processes a huge number of transactions every day, such as major e-commerce sites where a large amount of access is concentrated in an instant, and applies its know-how to off-app purchases. We have established an operational system to ensure that the system does not stop, such as pre-tuning based on load predictions at the time of events, so you can implement various measures with confidence.

(3) payment "Comprehensive strength" that covers the surrounding area

When you start off-app billing, you will have to do complicated tasks other than payment, such as refund to users, attracting customers to billing sites, and designing campaigns.

With GMO-PG, we can propose payment-related services such as Remittance Service (distribution through Amazon gifts, etc.), marketing support, security diagnosis, etc., as well as total solutions that take advantage of the synergy of the GMO Internet Group. We will not stop at just payment processing company, but support you from a long-term perspective as a partner for business growth.

Summary: Preparing for the Competitive Advantage Smartphone Act Brings

Smartphone Act provides app owners with fair competition and opportunities to improve their revenue.

[Actions to be taken by businesses]

• Check laws and regulations: Keep an eye on the guidelines of the Fair Trade Commission and changes to the terms of Apple and Google.
• Incentive design: Verify the "increase and discount benefits" that move users.
• payment Build a foundation: Choose an implementation pattern that is suitable for your company and consider how to build an environment that ensures security.

If you don't know where to start, don't worry. At GMO-PG, we will provide you with the best proposal according to your business scale and phase. Even if you're short on development resources, there's a way to start with a light deployment.

To minimize risks and reap the maximum fruits of reduced fees, start preparing today with our professional partner GMO-PG.